We thank CIFFA for sharing this information with us. 

On June 29, ...[CIFFA posted a blog post entitled] Prepare Now -- CBSA Planning to Cancel eHBL for Back-to-Back Shipments Clearing from a Primary Warehouse. Since then, CIFFA has had further meetings with the Canada Border Services Agency (CBSA), who are putting the final touches to the Customs Notice that will prohibit filing eHBL for release from the primary warehouse for back-to-back/single shipments.

The primary reason for the decision is the security gap that was created with the Deconsolidation Notice. The CBSA had to close that gap for both air and marine shipments. After months of analysis, it was determined that prohibiting eHBL for back-to-back/single shipments clearing from a primary warehouse was the only option. The 'effective' date of the change will be within a few weeks of the Customs Notice, which means that, in the marine mode in particular, forwarders will have only a few weeks to ensure that every shipment for which eHBL data was filed will be released and delivered from the terminal/railroad/airline warehouse before that effective date.

Realistically, marine cargo loading now should be 'rolled back' to the pre-November 2016 procedures. File ACI supplementary data (S10) and make the release request on the primary carrier's cargo control number (9000). Contact agents and overseas offices and stop eHBL for back-to-back/single shipments immediately.

If a forwarder has eHBL back-to-back/single shipments that are not cleared and delivered by the effective date of the Customs Notice, each eHBL will need to be cancelled, ACI supplementary data will need to be filed and the broker advised that the release request will be on the primary cargo control number. If the cancellation occurs before the shipment has arrived at the First Port of Arrival and the Carrier Arrival Certification Message (CACM) filed, the eHBL can be cancelled via EDI. If the shipment has been CACM 'arrived', the forwarder must file the BSF673 to cancel the eHBL...which will take days to process.

The change affects the air mode, too. If an eHBL is filed for a back-to-back/single air shipment clearing from the carrier's warehouse (primary), it will need to be cancelled, and the odds are that it will be noticed only after the FPOA arrival (CACM), which means that the form BFS673 will need to be completed. We' ve talked to the CBSA about speeding up the processing of those forms, especially during the time around the 'effective date', but nobody needs air freight delayed while a paper form is processed. Roll back your procedures now. File ACI supplementary data and make the release request on the carrier's MAWB.

On the other hand, we've had several reports that eHBL is working brilliantly for consolidated cargo clearing out of a CW sufferance warehouse. So, move forward and go paperless with all eHBLs clearing from a CW warehouse. Roll back to ACI supplementary data and release under primary for all single shipments clearing from a primary terminal/rail/airline warehouse.