CBSA's "20 HS Code" Requirement for PARS/RMD Imports Began Feb 1
In June 2011, the Canada Border Services Agency announced the phased-in timeframe for increasing the number of lines requiring a 10-digit HS code at the time of interim accounting (PARS and RMD requests). CBSA has reposted that notice as effective February 1, a minimum of 20 HS codes have to be reported at the 10-digit level, up from a minimum of 10 HS codes which took effect on September 1, 2011.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
(See ITT's Online Archives 11061714 for initial summary announcing these HS Code changes and their phase-in schedule, including the September 1, 2011 phase-in change that also applied to most Low Value Shipments (LVS).)
Minimum of 20 HS Codes Required as of Feb 1, to Increase to 30 on June 1
CBSA’s 2008 Memorandum D17-1-4 (Release of Commercial Goods) had required - in situations where more than five HS codes were applicable - a minimum of five codes at the 10-digit level to be provided for the release of the goods (where one of the five codes provided for either the (i) highest valued commodity of the shipment or the (ii) commodity that provided the most reasonable representation of the shipment).
In June 2011, CBSA announced that all lines will eventually require the 10-digit HS Code at time of release. CBSA provided importers, customs brokers and service providers a phased-in timeframe to increase the number of lines requiring a 10-digit HS code at time of interim accounting (PARS and RMD requests) from ten lines as of September 1, 2011 to all lines, as follows:
- February 1, 2012 -- Minimum of 20 HS Codes
- June 1, 2012 -- Minimum of 30 HS Codes
- January 1, 2013 -- HS Code for all lines up to 999 lines (or CBSA system capacity)
Requests Without Minimum Number of Required HS Codes to Cause Rejects
Release requests that do not provide the minimum number of HS Codes in accordance with these phases will not be accepted for processing and will be rejected back to the importer/broker. Requirements for the provision of a 10-digit HS Code are applicable to both paper and Electronic Data Interchange (EDI) interim accounting release requests.
(Note that in June 2011, CBSA provided a temporary "Zero-Class Code" as an interim solution for instances in which the importer/broker was unable to determine the 10-digit HS Code for a commodity. Additional information on the criteria for use of the "Zero-Class Code" is available here.)
CSA Importers Using PARS/RMD Exempt Unless OGD Rules
Custom Self Assessment (CSA) importers using PARS or RMD release options will continue to be exempt from providing HS Codes at time of release unless subject to Other Government Departments (OGD) requirements.
(See ITT's Online Archives 11052413 for summary stating that eManifest is the third phase of the Advance Commercial Information System (ACI) program and pertains to truck carriers. The first two phases pertained to air and marine carriers.
To increase the use of EDI and help meet the eManifest requirements, CBSA introduced "Phase I" measures in April 2008. These measures introduced the requirement for the electronic (EDI) transmission of Release on Minimal Documentation (RMD), including the "Pre-Arrival Release System (PARS)" release, and phased in the timeframe for increasing the (i) number of lines requiring a 10-digit HS code and (ii) the total number of invoice lines that trigger EDI transmission to CBSA.)
Memorandum D17-1-4 is available here.