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Update on Revenue’s Electronic Manifest System and its implications for clearance of SADs
1. Introduction
The purpose of this Notice is to further inform all relevant traders, and in particular Air and Sea Carriers, freight forwarders and customs agents, involved in the carriage of goods into and out of Ireland by air and sea, or involved in the customs clearance of those goods, of the current position regarding the implementation by Revenue of its Electronic Manifest System (EMS). To give notice of Revenue’s decision to impose appropriate sanctions from 1 July 2015 for failure to observe the legal obligation to submit correctly completed electronic manifests and SADs.
This Notice is a follow-up to Notice No. CDPN51, which was issued in March 2015.

 

2. Background
EMS has been live since October 2014. Since that date cargo manifests are legally required to be submitted electronically to EMS by Carriers of all goods being carried on board ships or aircraft coming into, or departing from, the State.
Since its release in October 2014, the EMS has been operating in what is termed “interim matching mode” in respect of third country goods being imported into the EU and listed on a manifest. This means that while Revenue’s systems are attempting in the background to match the third country goods listed on a manifest against the corresponding SADs that should be lodged for those goods (i.e. to automatically write off the goods on a manifest against a SAD for those goods), the clearance of the goods declared on the SAD has not been held up if no match is found.
It was intended that this “interim matching mode” would cease on 30th June 2015 and that from this date failure to match the manifest data against the SAD data would result in the non-release of goods.
(Note: For the purposes of matching goods listed on a manifest against goods declared on a corresponding SAD, the matching fields are: ID of Means of Transport (either IMO No. of Vessel or Flight No.), Estimated Date of Arrival/Departure, Transport Document Type and Number, Unique Line of Package Reference, Number of Packages.)
CDPN52
3. Current Position
Engagement by trade to date with the EMS has been disappointing on a number of fronts:

  • While the majority of Carriers are now lodging electronic manifests, not all Carriers are doing so, even though there is a clear legal obligation on them to do so;
  • The quality of data on the manifests that are being lodged electronically is sometimes poor; and
  •  In some instances, a sufficient level of data to allow for matching between Manifests and SADs is not being provided.

The combination of all of the above factors has resulted in unsatisfactory levels of matching between Manifests and SADs. If Revenue were to switch the matching functionality from “interim matching mode” to “full matching mode”, and hold the clearance of goods until the matching of goods on a SAD against a Manifest had occurred, it is anticipated that significant volumes of goods would be held up.

4. Next Steps

In the circumstances, Revenue has now decided that the move from “interim matching mode” to “full matching mode” will not happen from 1st July, as was intended. Revenue will continue to work with Manifest and SAD declarants over the coming period in an effort to ensure that the matching rates between Manifests and SADs increase significantly. A further notice will issue in the coming months to detail the activation of full matching mode.
However, the requirement on all Carriers to lodge electronic cargo manifest information to EMS, which adheres to the data specifications, message structure, format, rules and conditions as published by Revenue, has existed since October 2014, including the requirement that a single manifest is normally required for all goods on board a particular means of transport.
The deferral of the functionality relating to “full matching mode” does not in any way diminish the responsibility of Carriers to lodge electronic manifests and to ensure a high quality of data in all submissions to Revenue.
From 1 July 2015, sanctions will be imposed on:

  • Non-filers of electronic cargo manifest to EMS; and

 

  • Filers of poor quality data to EMS or AEP.

These sanctions will include, but may not be limited to:

  • Application of appropriate penalties;
  •  Issuing of instructions from Revenue that a ship or aircraft cannot be unloaded; and
  • Negative impact on any authorisations for simplifications that are currently in place.

Instructions in this regard are issuing to relevant Revenue staff. In the circumstances it is imperative that all Carriers that are required to lodge cargo manifests to Revenue do so through the EMS. In addition, all SAD declarants should ensure that the data provided on such declarations is correct.