On January 4, 2021, it became mandatory to submit both the eHBL data and the Close Message no less than 24 hours before the vessel is loaded at Antwerp. However, there is no obligation to transmit the ACI S10 Supplementary data. Your company must determine which entity will file the eHBL data set/ Close Message and utilize whose (bonded?) 8000 code.
You are accurate in stating that if each house bill (and eHBL) is addressed to the importer/ consignee and the 8000 CCN is used in the Customs release request to clear the cargo, the Consolidated Indicator would be “No”.
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