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China Customs Advanced Manifest: New Requirements for Imports and Exports

Introduction

As of June 1, 2018, the General Administration of Customs of the People's Republic of China (GACC) has implemented new China Customs Advanced Manifest (CCAM) requirements for imports and exports. These changes, outlined in GACC Announcement No. 56, introduce significant modifications to the data that must be electronically shared with Chinese customs authorities for all inbound and outbound shipments. In this article, we'll explore these new requirements and their implications for businesses engaged in international trade with China.

Key Changes in CCAM Requirements

The new CCAM regulations bring several important changes that shippers, consignees, and freight forwarders need to be aware of:

1. Advanced Manifest Submission

One of the most significant changes is the requirement to submit the Advanced Manifest to China Customs 24 hours prior to cargo loading on vessels sailing to or from mainland China ports. This early submission allows customs authorities to review shipment information well in advance, potentially streamlining the clearance process but also requiring more proactive planning from shippers.

2. Accuracy and Completeness of Manifest Data

The new regulations emphasize the need for accurate and complete manifest data for all goods under the Bill of Lading (BL). This means that shippers must ensure that all information provided is precise and comprehensive, leaving no room for ambiguity or missing details.

3. Detailed Shipper and Consignee Information

Full details of the Shipper and Consignee (or Notify Party if the Consignee is To Order) must now be provided in the shipping instruction (SI). This increased level of detail aims to enhance transparency and traceability in the supply chain.

New Enterprise Code Requirements

Perhaps the most notable change in the CCAM requirements is the introduction of mandatory Enterprise codes for all parties involved in the shipment. These codes vary depending on whether the entity is based in China or elsewhere:

For Chinese Entities

Chinese shippers, consignees, and notify parties must provide one of the following:

  • Unified Social Credit Code (USCC): If available, this should be provided in the format "USCI + USCC code"
  • Organization Code (OC): If no USCC is available, the organization code should be provided in the format "OC + organization code"

For Non-Chinese Entities

Shippers, consignees, and notify parties outside of China are also required to provide an Enterprise code. However, the specific code varies by country. Some examples include:

  • Japan: Legal Entity Identifier (LEI)
  • USA: Employer Identification Number (EIN) or Central Index Key (CIK)
  • UK: Company Number or VAT Number

Implications for Individual Shippers and Sole Proprietors

The new requirements present a unique challenge for individual shippers and sole proprietors, particularly those based in the United States. For these entities, the GACC may require the submission of personal Social Security Numbers (SSNs) to satisfy the new regulations. However, this raises significant privacy and security concerns.

To address this issue, we strongly recommend that individual shippers and sole proprietors consider the following steps:

  1. Obtain an Employer Identification Number (EIN): This can serve as an alternative to providing a personal SSN. The process of obtaining an EIN from the IRS is generally straightforward and low-cost.
  2. Consider Incorporating as an LLC: For those engaged in regular international trade, forming a Limited Liability Company (LLC) can provide an additional layer of protection and separation between personal and business activities.

Potential Impacts on International Trade

The implementation of these new CCAM requirements is likely to have several significant impacts on international trade with China:

1. Increased Data Collection and Management

Businesses will need to collect and manage more detailed information about their shipments and trading partners. This may require updates to existing systems and processes to ensure compliance.

2. Potential Delays in Shipping Processes

The requirement to submit manifest information 24 hours before loading could potentially lead to delays, especially in the initial stages of implementation as businesses adapt to the new timeline.

3. Enhanced Supply Chain Transparency

While potentially challenging to implement, these requirements are likely to result in greater transparency throughout the supply chain, which could lead to improved efficiency and reduced fraud in the long term.

4. Privacy and Security Concerns

The collection of sensitive identification information, such as SSNs for individual shippers, raises important questions about data privacy and security that will need to be addressed.

How FreightAmigo Can Help Navigate These Changes

At FreightAmigo, we understand that these new regulations may seem daunting, especially for businesses new to international trade or those without dedicated compliance teams. As a Digital Logistics Platform, we are well-equipped to help our clients navigate these changes effectively:

1. Automated Document Management

Our Digital Platform includes advanced features for automating shipment documents. This can help ensure that all required information, including the new Enterprise codes, is accurately captured and submitted in compliance with the CCAM requirements.

2. Real-Time Tracking and Updates

With our ability to track shipment status anytime, anywhere, we can help ensure that your Advanced Manifest is submitted within the required 24-hour window before cargo loading.

3. Customs Clearance Assistance

Our 1-stop service for arranging customs clearance can be invaluable in navigating the complexities of the new CCAM requirements, helping to prevent delays and ensure compliance.

4. Expert Support

Our 24/7 logistics expert support team is always available to answer questions and provide guidance on the new regulations, helping you adapt your processes as needed.

5. Comprehensive Digital Logistics Solution

As a full-service Digital Logistics Platform, we offer a range of integrated services that can help streamline your entire shipping process, from quote comparison and booking to document management and customs clearance.

Conclusion

The new China Customs Advanced Manifest requirements represent a significant shift in the landscape of international trade with China. While these changes may initially present challenges, they also offer opportunities for businesses to enhance their supply chain transparency and efficiency.

At FreightAmigo, we are committed to helping our clients navigate these changes successfully. Our Digital Logistics Platform is designed to adapt to evolving regulatory requirements, ensuring that your business can continue to trade seamlessly with China and beyond.

As we continue to monitor the implementation and impact of these new regulations, we encourage businesses to stay informed and proactive in their approach to compliance. By leveraging the right Digital Logistics Solutions and expert support, you can turn these regulatory challenges into opportunities for growth and improved operations.

For more information on how FreightAmigo can support your business in adapting to these new requirements, please don't hesitate to contact our team. We're here to ensure that your logistics experience remains hassle-free and enjoyable, even in the face of regulatory changes.