The CBSA issued a new Customs Notice on mandatory electronic house bills, which advises that in cases where freight forwarders are NOT ready to transmit eHBLs (electronic House Bills of Lading), the pre-existing process of submitting supplementary data and presenting paper house bills can continue to be used.  If house bill and / or supplementary reports are on file and in good standing for a consolidated shipment, the shipment will continue to move.  According to the notice, CBSA will provide "adequate notice" as to when supplementary data will no longer be accepted". The notice also states that the requirement to transmit eHBLs and supplementary data is the responsibility of the freight forwarder (who is defined as "a person who, on behalf of one or more owners, importers, shippers or consignees of goods, causes specified goods to be transported by one or more carriers").  Accordingly, freight forwarders who meet this definition may transmit supplementary data or house bill data using their own carrier code. SeaLand will continue to submit supplemental bills until otherwise directed by CBSA, but will not submit eHBL data on behalf of freight forwarders. The implementation timeline for eHBL remains the same as previously announced, i.e.:
  • November 7, 2016 to January 10, 2017:  Transitional period during which there will be no penalties for non-compliance and CBSA will work closely with freight forwarders on corrective measures
  • January 11 to July 11, 2017:  Non-compliant freight forwarders may be issued zero rated (non-monetary) penalties
  • July 12, 2017 onwards:  Non-compliant freight forwarders may be issue monetary penalties
A Sub Location Code is an identifier of the primary location/warehouse where the goods are to be stored pending clearance.