Until everyone is filing eHBL and Close Messages within the required timeframes (at least 24 hours prior to load), multi-tiered consolidations are likely to face significant issues. From November 1, 2020 to June 4, 2021, cargo will load on an ACI S10 Supplementary filing and a paper Customs release request. To avoid problems, CIFFA advises NVOCCs and master co-loaders to establish and communicate business rules governing the consolidation process and to set firm deadlines for filing eHBL data, ideally well before January 4, 2021. These rules should apply to all freight forwarders in the consolidation who issue a house bill consigned to another forwarder, and should require them to file an eHBL with a Consolidated Indicator Yes.