Further to our earlier updates communicated on the India Sea Cargo Manifest (SCMT) Regulations, as advised by the Central Board of Indirect Taxes and Customs (CBIC) vide their latest Notification No. 39/2021-Customs (N.T.) dated 31 March 2021, the SCMTR will come in force effective 15 April 2021.
We understand Indian Customs have already readied their systems to digitally accept the Shipping Documents from various stake holders. Indian Customs have also advised all Shipping Lines to come forward to conduct parallel testing of EGM (Export General Manifest) & IGM filing.
While we have embarked upon conducting parallel runs for due submissions of Sea Arrival Manifest (SAM) and Sea Departure Manifest (SDM) with ICEGATE, we earnestly request our customers to kindly come forward and be ready to meet the migration that is expected effective 15 April 2021.
We would like to draw your attention on the main requirements of SCMTR.
Sea Arrival Manifest (SAM)
Import manifest will now be known as Arrival Manifest and Shipping Lines will be required to submit details of all import, transshipment & onboard containers to Indian Customs prior to departure or vessel sailing from the last port of call before calling India ports
For the shipments discharging/destined to Indian ports, the Arrival Manifest (SAM) should also include following data elements
- HSN Code (6 digit numeric)
- IEC (Importer Exporter Code) of the Consignee (If IEC not available, PAN of Consignee should be mentioned)
- PAN (Permanent Account Number) of Notify/consignee
- The House Bill of Lading (HBL) information needs to be declared in the SAM prior departure from the last port of call.
Arrival Manifest Requirement
Submit all IGM/SCMT relevant information, House Bill of Lading (HBL) or Cargo Summary Notification (CSN) preferred Container Freight Station (CFS) details etc. to Hapag-Lloyd at least 72 hours prior to vessel sailing from last port of call before calling Indian ports.
Important note: For transshipment and in-transit (FROB) containers, above data elements are not required. However, complete Bill of Lading information is required to be available 72 hours prior to vessel sailing from the last port of call.
Sea Departure Manifest (SDM)
Export manifest will now be known as Departure Manifest and Shipping Lines will be required to submit details of all export containers to Indian Customs prior to departure of the vessel.
Departure Manifest (SDM) should also include following data elements.
- HSN Code (6 digits – numeric)
- IEC code of Shipper/Consignor (if IEC not available, PAN of shipper/consignor should be mentioned).
- PAN (Permanent Account Number) of Shipper
- PCIN (Primary Cargo Identification Number) – Date (yyyy-mm-dd)
Important note: The above information must be submitted in Shipping Instructions for exports.
With regards to Sea Arrival Manifest (SAM) and Sea Departure Manifest (SDM), CBIC authorities had further clarified as follows
- PCIN (Primary Cargo Identification Number) will be generated by Customs whenever an actual shipper and consignee manifest the House Bill of Lading for Imports or the LEO (Let Order Export) Shipping Bill for Export cargoes.
- CSN (Cargo Summary Notification) will be generated by Customs when a forwarder/consolidator files the House Bill of Lading (HBL)details using CSN format.
- MCIN (Master Cargo Identification Number) will be generated by Customs when details of HBL matches with details of Master Bill of Lading (MBL) with respective CSN or SAM / SDM file.
Departure Manifest Requirement
In order to comply with SCMT deadlines, we will be implementing revised Cut-offs for Export Cargo. Please refer to our website for the cut-offs to be followed for each of our services.
You are kindly requested to submit the PCIN (generated post filing of LEO Shipping Bill) or the CSN (generated by Forwarders/Consolidators generated) to Hapag-Lloyd within the cut-off deadline.
In case CSN not generated by Forwarders/Consolidators, the House Bill of Lading (HBL) data together with PCIN should be submitted to Hapag-Lloyd within the cut-off announced.
Important note: There is no change in the current practice of sending Shipping instruction along with house BL for AMS and Canada filing. However, E-HBL for SCMT is a separate process to be submitted on ODeX
Any amendments post filing of SAM or SDM will be subject to the approval of Indian Customs Authorities and will attract customs penalties/fines.
Switch Bill of Lading
Switching of Bill of Lading will not be allowed for the containers which are loaded from last port of call before India (Local export), Switching of BL for containers loaded from other ports is still allowed but must be completed before 72 hours of vessel sailing from the last port of loading before India.
Change of destination (COD)
COD will be allowed only 72 hours prior to vessel departure from last port of call. Any change in Bill of Lading information after this deadline may result in discrepancies with the Sea Arrival Manifest), resulting in fines and penalties.
For local information requirements with regards to HBL filing requirement, CFS / DPD nominations, SEZ declaration; with SCMTR this cutoff will be revised to 3 working days prior to vessel arrival to last POL.
COD will not be processed unless and until relevant changes are made to the shipping bill and required evidence regarding the same is submitted to the shipping line.
We have collaborated with ODeX to provide Online solution for submission of SCMTR related manifest data filing submission. Please refer to below links for ODeX registration and to access the manuals on e-HBL, e-Shipping Bills, e-CFS submissions.
What do Customers need to update in ODEX portal:
- Shipper to upload PDF Shipping Bill on ODeX system. In addition to PDF file, Shipper will have to either upload PCIN # /
- Shipping Bill EDI file/Excel file or update all data required for SDM filing purpose in ODEX system. (This is for validating the information for successful filing).
- House Bill of Lading or CSN Number per the case to be furnished in ODEX portal in advance.
- Any such variations / inconsistencies between the MBL, HBL & S/Bill Data – Exception / Rejection Report, Mismatches If any / Errors will be communicated to the shipper instantly who has to revert with corrections soonest by return.
Common for exports & imports required to be submitted by customers:
- Shipper IEC Code would be required for SDM filing.
- Consignee IEC Code would be required for SAM filing.
- Notify Party PAN Number would be required for SAM filing
- The local legal identification is required wherever an Indian party is involved (as Shipper, Consignee or notify party).
Note: In case the shipper, consignee / notify party appearing in the bill of lading is a NVOCC / Freight Forwarder, then PAN number of the entity will have to be declared in the bill of lading.
What is expected from the Registered & Un-registered users under SCMT regulation?
- Registered Users: (Customers registered with Customs for self-manifest filing under SCMTR)
- They must submit / file their HBL details to Customs giving Carrier MBL Number reference and in return obtain the CSN (which can be shared to the Carrier via ODeX).
- They also have an option to share their full HBL filed in ODEX to the carrier.
- Unregistered Users: (Customers who prefer the shipping line to file the manifest on their behalf)
- Will have to submit their HBL details to Carrier along with MBL SI Details.
- Incase multiple forwarders involved, they shall share details to NVOCC / Consolidators.
Mandatory Inputs to tally the Carrier MBL that will be a precursor to successful CSN/ SAM / SDM Filing:
- Number of Packages
- Container number
- Size, Seal Number
- Six Digit HS Code
- MBL No. & Date
- Overall Gross Weight (in every HBL)
IMPORTANT NOTE: If multiple HBL’s in an MBL, then the counts in every HBL MUST Tally with the count in the MBL
List of important & mandatory details required for CSN / SAM filing:
- Consignee IEC, PAN, GST, Email details are mandatory.
- IEC to be replaced with PAN if FFDR / NVOCC is appearing as Shipper / consignee in MBL.
- For imports into India if consignee is ‘TO ORDER’ / ‘TO ORDER OF SHIPPER’ / BANK then PAN & IEC of Notify must be present.
- HS Code: (applicable for India Export – Import cargo only): 6-digit HS (Harmonized system) code & filing of HS Code wise cargo description in the bill of lading and customs manifest. (This needs to be submitted at booking stage).
- Complete and accurate Bill of Lading information needs to be available 72 hours prior to vessel arrival at the Last Port of call.
- HBL / CSN # to link with carrier MBL while furnishing in ODEX, 72 hrs. prior to the vessel arrival to the last port of call.
List of Important & Mandatory details required by shipping lines for CSN/SDM filing:
In addition to the standard practice of forwarding the Shipping Instructions and House Bill of Lading data (for 24 hours Advance Manifest regulated Countries), from SCMTR perspective following needs to be adhered to:
- Sea Departure Manifest will be based upon the Bill of Lading information and not based on Customs Shipping Bill as is the practice today. Accordingly, it is imperative that the complete and correct Shipping Instructions are submitted by Customers within the agreed timelines.
- Special care must be taken to ensure that the mandatory fields required for submission of Sea Departure Manifest are correctly declared in the Shipping Instruction (SI) and matches with the information filed in the Shipping Bill. If any discrepancy / error during Sea Departure Manifest filing to this reason may result in de-manifestation from the Sea Departure Manifest and associated cost / consequences on account of the booking party.
- On filing of Shipping Bill with customs, a PCIN number will be generated which needs to be provided to Shipping Line, we will in turn link the same with the Bills of Lading information filed via Sea Departure Manifest.
- For consolidated cargo, CSN – Cargo Summary Notification maybe generated to incorporate information of all PCIN included in a single Master Bill of Lading.
Mode of declaration of PCIN / CSN to shipping line will have to be made through ODEX only.