As a part of the Freight & Trade Alliance (FTA) and Australian Peak Shippers Association (APSA) combined submission to the Federal Inquiry into Freight & Supply Chain Priorities, it was recommended that import border hold processes be reviewed in line with the following recommendations :
Container Examination Facility (CEF) targeted containers have storage arrangements prescribed in Melbourne, Brisbane and Fremantle ports to meet the extended storage benchmark established in Sydney under the Port Botany Landside Improvement Strategy (PBLIS) Mandatory Standards – clause 17; and
extended container detention periods be provided by shipping lines whereby cargo has been reported in terms of statutory requirements with evidence that delayed release from the stevedore is due to CEF intervention.
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Commonwealth Ombudsman
Continuing this advocacy, FTA / APSA met with the Commonwealth Ombudsman's office in Canberra on 19 September 2017 on issues relating to border compliance of containerised sea cargo providing examples of duplication of government department processing and other instances of excessive delays in cargo release.
FTA / APSA raised the complexity and difficulty associated with the profiling by the Australian Border Force (ABF) when an importer moves to use the services of a new customs brokerage. While noting the concern, the Ombudsman made it clear that the ABF targeting / profiling falls outside the scope of their investigation. FTA / APSA will continue advocacy and the need for reform on this matter direct with the ABF.
The Ombudsman's office also sought specific feedback from FTA / APSA in terms of the annual Import Processing Charge (IPC) and industry complaints received in relation to the lack of notification of releases.
REFERENCE:
Import Processing Charge
FTA / APSA made reference to the most recent Australian Competition and Consumer Commission (ACCC) container stevedoring report which states that non-stevedoring revenue is reducing on a per TEU basis but remains high in an environment where there has been a significant decrease in the number of containers remaining in terminals beyond the fee-free period.
FTA / APSA suggested investigation whether stevedores are "compensated" by the Department of Immigration and Border Protection for delays in release for CEF targeted containers and if so, whether this is an appropriate use of IPC fees. FTA / APSA noted, at minimum, that stevedores should not receive this additional revenue at Port Botany as they are regulated to give extended storage as a part of the PBLIS Mandatory Standards.
Clause 17 of the PBLIS mandatory Standards states "the stevedore must not require the payment of any charge in respect of the storage of that container for the day the container is returned to the stevedore's terminal and for the next 2 working days after that day".
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Notification of Release
The Ombudsman gave advice that complaints have been that notice is not given when a hold on cargo is released.
FTA / APSA corrected this misconception explaining current systems functionality and outlining residual operational complexities. While notification of release is automated via the Integrated Cargo System (ICS), it does not assist industry in managing an efficient transport schedule as it is impossible to predict in advance when a CEF hold will be released.
FTA / APSA provided advice that the ICS provides a CARST (Cargo Status) Message. When cargo gets a Consolidated CLEAR status, a CARST advising the cargo is clear, is sent to the Cargo Reporter (of the lowest level bill), the customs broker / importer who lodged the Import Declaration and the Sec 77G Depot / stevedore or cargo terminal operator who has possession, custody and control of the cargo.
In response to industry requests nearly a decade ago, the then Australian Customs Service also introduced a Declaration Status Advice (DSA) message that provides further detail for the entity that lodged the Import Declaration.
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FTA / APSA have endorsed a concept suggested by the Ombudsman for an "Australia Post" model that deploys a text message system for its parcel post. The system sends two texts per delivery. One to advise that a parcel is on its way and one to confirm delivery or return to depot. Australia Post currently delivers 11.5 million parcels per week and the system has the capacity to service this amount of deliveries. Considering that the Australian Border Force (ABF) inspects 101,500 TEU per year, an opportunity exists to expand the ICS, or develop an alternate alert system in line with service standards established by other government agencies.
Further information
Please refer to the recent FTA / APSA trade media commentary as a part of our advocacy for genuine reform and an operational notice aimed at assisting members in best managing current operational procedures.
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We need your Feedback
Please share any information, views or examples that will assist the investigation on how regulatory powers are being exercised at the border and how it impacts on the supply chain - please send your feedback to pzalai@FTAlliance.com.au
Paul Zalai – FTA / APSA