All freight forwarders who use a bonded or non-bonded carrier code must transmit electronic house bills (eHBs) and house bill close messages about issues of non-compliance. The CBSA has noticed two scenarios in which freight forwarders and carriers are moving unreleased goods in Canada without authorization.
In scenario 1, when eHBs are destined to an inland sufferance warehouse and the primary cargo control document (CCD) is destined to a sufferance warehouse at the first port of arrival (FPOA), a deconsolidation notice is issued when the primary CCN arrives. This notice permits eHBs to exit the warehouse and proceed to their destination at the inland sufferance warehouse. However, in some cases, the carrier or freight forwarder contracted to pick up the shipment(s) is delivering the shipment(s) to the importer/consignee instead of transporting them to the inland sufferance warehouse. The delivery of unreleased goods is prohibited and may result in an Administrative Monetary Penalty (AMP) under Contravention C033. The penalty will be assessed against the owner of the carrier code on the CCN for the shipment. In this scenario, it would be the freight forwarder who transmitted the eHBs.
In scenario 2, movement between warehouses is not allowed under a non-bonded freight forwarder’s liability and carrier code. However, in some instances, eHBs with a non-bonded CCN are being moved from the primary sufferance warehouse to an inland sufferance warehouse by a carrier or freight forwarder who is contracted to do so. The movement of unreleased goods by a carrier or freight forwarder who is not bonded is prohibited and may be subject to an AMP under Contravention C036. The penalty will be assessed against the owner of the non-bonded carrier code on the CCN for the shipment. In this scenario, it would be the non-bonded freight forwarder who transmitted the eHBs.
It is important that trade chain partners communicate with each other to ensure that CBSA requirements are being met. Freight forwarders should familiarize themselves with eHB requirements and the requirements concerning the movement of unreleased goods in Canada.
The CBSA provides various publications and website references to help freight forwarders understand their requirements. Additionally, the CBSA is holding Implementation Telephone Sessions for freight forwarders concerning the recent R2 Release. For policy questions related to cargo, conveyance and house bill pre-arrival and reporting requirements, as well as sufferance warehouse cargo control and arrival requirements, please contact the eManifest Help Desk. For technical questions related to a specific shipment, please contact the Technical Commercial Client Unit (TCCU).
