Global Freight Forwarders Associations Criticise Advance Security Declarations

WORLDWIDE – Today FIATA, the International Federation of Freight Forwarders Associations, published its Position Paper on the Dual Filing for advance security declarations in accordance with the World Customs Organization (WCO) SAFE Framework of Standards and, whilst acknowledging the authorities’ prerogative to decide on the value of data elements in terms of risk analysis expressed extreme concern that good and cargo declarations may be merged together by Governments and thereby passing on responsibility to carriers where none previously existed.

The current SAFE clearly distinguishes between transport and trade transaction related information. This is a logical choice, and there is concern within FIATA’s membership that some governments or governmental organisation may deflect from this approach to compress advance electronic data requirements into a Single Filing System. Taking direct responsibility for information regarding the nature of goods within consignments would leave carriers in an invidious position where they would not have the realistic possibility of establishing that declarations made to the forwarder are always correct yet being held responsible if something was to be found amiss.

It is of course the task of the stakeholders to provide the authorities with good recommendations on the best possible ways in which the information required is to be submitted, by the party that has that information, with the least possible disruption for the supply chain and in line with existing, long established international trading practices, many of which are reflected in a series of international conventions. Stephen Morris, Chairman of the Customs Affairs Institute of FIATA, makes the following comment:

“FIATA has consistently taken the view that the definition of the data‐elements to be provided and the person or persons responsible for providing them cannot be artificially dissociated. It is not acceptable to encourage national authorities to create a legal requirement for a party to provide information that it does not have or run the risk of create turbulence in different parties’ legitimate and long established proprietary and confidential business arrangements.

“We work in a supply chain where each party has clear rights and responsibilities, normally in respect of its immediate interlocutors. Artificially altering these arrangements may damage the interest of some of them, but more importantly it may really deteriorate the quality of data. What may appear at first sight as saving, experience tells us costs more money in the end; a wise investment in due time is the best economy governments can make.”

The Position Paper can be read in full HERE.