With all the APEC (Asia-Pacific Economic Cooperation) countries having now implemented some level of a Single Window system for the processing of Customs documents, great efficiencies have been realized in each economy. Giving an international trader a single access-point to interact with Customs and OGD’s (Other Gov’t Departments) to exchange documents and information has unquestionably helped to raise GDP in each participating country.
What if further efficiencies could be gained by integrating the various National Single Window (NSW) Systems? This is by no means an easy task and the topic of international interoperability and adoption of international standards requires in-depth research to properly understand the potential issues on achieving successful international interoperability among the participating governments.
Taking an in-depth look at each APEC NSW is required and obtaining the information below to understand if there is a willingness to participate and if the project is technically feasible.
- Use of WCO Data Model and or use of International Standards
- Messaging technology used
- Governance (PKI, tokens, PIN/Passwords, BS7799)
- IT Infrastructure
- Openness to adopting international interoperability
- How responsive is the receiving NSW to requests from another NSW
- NSW autonomy
Some potential types of documents that are suitable for data exchange among the NSW systems include;
- eCO (Electronic Certificate of Origin)
- Phytosanitary Certificate
- Veterinary Certificates (EU Customs Single Window currently exchanging 3 different certificates)
- NAFTA Certificates
- Certificates related to Food Safety (Canada has just implemented import & export licencing requirements for food importers & exporters.
Document data could either be passed in PDF readable format or have the document dematerialized by entering a document number in the NSW or RSW. The PDF document details of the matching export licence number would be shown upon successful verification of the licence number.
Both CBP and CBSA have included document image functionality in their respective NSW systems (ACE-Automated Commercial Environment) and ACI (Advance Commercial Information). Blockchain is also being used now in the case of certificates of origin where authenticity is of paramount importance.
Supply Chain Security (SAFE)- Advance Cargo Information (eManifest)
Often the submission of pre-arrival manifest data is required 24-hours before loading the cargo at the foreign port for ocean shipments. This obviously can pose challenges for smaller transportation companies who do not operate 24x 7. This will often lead the transportation company to work with their overseas agent to coordinate and collaborate the sending of advance eManifest data to Customs. This type of collaboration among smaller companies often leads to data quality issues. Large fines for missing filing deadlines or inaccurate eManifest information are common. The fines for non-compliance in Canada and the US range from $2K to $10 per occurrence which are detrimental to a smaller business.
If export manifest data also became mandatory to be submitted electronically to the respective NSW, that data could pass through the RSW. This can prevent redundancy from advance trade data requirements such as “10+2” requirement from CBP (Customs & Border Protection) which are a requirement of the US importer to be submitted.
Canada is also looking at supplementary advance trade data know as ATD (Advance Trade Data). “10+2” or ATD exist because the current import manifest data is either incomplete i.e manufacturer is missing which was a problem when the Yemen incident occurred where bombs disguised as printers were discovered. Or the import manifest data is received too late to conduct a proper risk assessment. The sharing of export manifest and export declaration data can help to fill this gap while lifting the importing carrier and importer from the abundance of import eManifest data filing requirements.
Previous import/export data sharing initiatives have already taken place. In 1996, the Group of Seven Industrial Nations (Canada, France, Germany, Italy, Japan, the United Kingdom and the United States) agreed to an undertaking to simplify the customs process by harmonizing data required by traders to conduct business between the G7 countries. Datasets and standardized data electronic messages for electronic data interchange (EDI) were developed to enable traders to reuse much of the information submitted to satisfy exporting requirements from one G7 country while meeting the importing requirements of another G7 country. The work completed by the G7 Initiative is the basis for data simplification and harmonization work being undertaken by the World Customs Organization (WCO) to introduce an international standard. This G7 initiative has had questionable success due to the requirements of Customs Agencies to data harmonize.
If all National Single Windows’ adopted the same WCO Data Model, moving to integrate the National Single Window systems might be an easier task. However, that is not the case with each system using a variety of data formats including;
- ANSI X12
- Proprietary Formats (CBP data formats CATAIR, AESTAIR, CAMIR)
Achieving data harmonization among the NSW’s is not something that will happen any time soon. There are simply too many Customs Agencies to reach an agreement and the time it takes to change is too long. If CBSA can share an export declaration in UN/EDIFACT format can it be received by CBP who uses their own proprietary format CATAIR?
Using technology or help from the private sector can fill this gap. Translation services are common these days and can be used so that a NSW using UN/EDIFACT can be translated and consumed by the CBP system using CATAIR.
Trade continues to grow exponentially, and the NSW has facilitated trade for each economy. As each gov’t NSW matures the ultimate last step is to reach an RSW for the APEC region to multiply the benefits that each economy is already enjoying. Reaching this goal is going to require slow and eventual data harmonization among the members but until that time is reached, using translation technology so each NSW can speak the same language without having to learn the language makes a lot of sense.