In the marine mode, late filing penalties may not be the problem. The problem is the container may not load if all of the eHBL data and Close Messages have not been filed. If the co-loader fails to send its 8000 eHBL data to its customers far enough in advance to allow its customers (and all of the customers in tiers) to file the 8000 eHBL data, then whoever in the chain failed should be held responsible. CIFFA is urging every freight forwarder issuing a “Consolidated Indicator Yes” eHBL to establish business rules regarding timing and communication and whose shipment is allowed into the consolidation.