SA Revenue Service Customs (Sars) has refocused its approach to implementation of the New Customs Act Programme (NCAP) and has identified Reporting of Conveyances and Goods (RCG) as its first priority.
The first phase of RCG is due to go live next month (April) when it will become mandatory for all cargo reporters in the air, sea and road industries to submit reports to Sars electronically. These include carriers, customs brokers, port/airport authorities, terminals, depots and registered agents.
In this first phase every cargo report in the supply chain will need to be submitted electronically – and this includes the manifest, the outturn report, gate-in/gate-out report, container discharge and loading report and arrival information. While electronic submission of cargo reports has been mandatory since 2009, it hasn’t been enforced.
“We believe industry has had more than enough time to comply,” said Sars executive – customs & excise Centre of Excellence, Beyers Theron. “Once we have RCG implementation bedded down we will enforce the mandatory submission of cargo reports throughout the supply chain.”
The roadfreight industry appears to be best prepared. According to Theron, at the last report, 89% of roadfreight operators were compliant.
“This almost becomes acceptable because we understand we will struggle with international hauliers. Only 55% of seafreight operators are compliant while airfreight is the least compliant at 24%.
“Anyone operating within the supply chain needs to make sure they meet the reporting requirements under section 8 of the legislation,” said Theron. “And this ranges from the carriers to freight forwarders and parastatals that play in the port and airport environments.” Declarations are matched at the lowest denominator which is house level – and Sars starts creating exception reporting cases from there.
“Without that 45% of seafreight data you have the possibility of creating 45% plus exception cases which is why it’s critical that we meet that compliance relatively soon.”
RCG implementation will begin on April 20 – with a three-month stabilisation phase. “During that pilot phase we will work with our offices to ensure they are stabilised, that the system is stabilised and that the industry is stable in terms of usage of the system. We also won’t enforce a penalty regime, but once that grace period is over – and we’re aiming for August 1 – the system will be fully functional with enforcement of reporting requirements under the legislation.”
Sars has started internal line briefings ahead of the launch. “Every second week we do a line briefing so that people on the ground know what’s happening. We will extend that to trade – and those external briefings will be published on the Sars site.”
According to Theron, it’s a very big implementation. “Externally it forces the industry into a new compliance culture. We are gradually moving to an environment where it could be to the detriment of the importer or exporter if data from the supply chain doesn’t meet data in the declaration. So working towards that is sizeable.”
In addition, there’s never been reporting on the export side which adds a new dimension. National implementation on April 20 will focus on road freight.
“For them it will be an architectural system switch. We’ll deploy specialists and training champions to help at the borders and set up a central command in Durban.” And while for road freight it’s just a technology switch, for sea and air it will be a steep learning curve.
“We’re concentrating the pilot in Durban and for the first month we’ll attend to glitches and start working with teams on the ground. Eventually, in a future sub-phase, submission of data will go into the risk engine and the risk engine will send it for documentary inspection. At this point we don’t have that risk engine.”
Once Durban has been stabilised, the system will be rolled out to other ports, and once that’s stabilised, to OR Tambo International Airport and the airfreight environment. From April to mid-June, seafreight will be stabilised and from the end of June airfreight will be the focus. If all goes according to plan, August 1 will see full implementation.
The objective of NCAP is to modernise the customs systems to facilitate legitimate trade and protect the supply chain. Due to the size and scale of the programme it has been broken down into more manageable chunks. RCG is one of three major projects – the other two being Registration, Licensing and Accreditation (RLA) and Declaration Processing (DPS).
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If all goes according to plan, August 1 will see full implementation. – Beyers Theron