Advance Filing Rules: Japan’s Customs Clearance Process
Global Customs Trends – Japan’s Ocean Advance Filing Rules (AFR)
1. AFR Regulation Basics
As of March 2014, vessel operators and NVOCCs are required to electronically submit to Japan Customs information on maritime container cargo to be loaded on a vessel intended for entry into a port in Japan. Paper filings are no longer accepted. In principle, these filings should be submitted no later than 24 hours before departure of the vessel from a port of loading. Unlike other global advance manifest regulations, however, the exact timing for AFR filings to Japan Customs depends on where the cargo originates and which Japanese port the freight is destined for. For more information and for a comprehensive matrix of anticipated cut-off times and country-of-origin submission, details can be accessed on the Japan Custom’s website at http://www.customs.go.jp/english/summary/advance/annex02.pdf
While the vessel operator or NVOCC is the party responsible for the AFR filing, they must obtain the necessary data elements from the shippers in order to ensure compliance. As such, shippers are likely to receive requests for information on data elements from their vessel operators and/or NVOCCs. Shippers need to ensure that the appropriate data is provided in an accurate and timely manner to their logistics services provider.
2. Filing Exemptions
Filing is required for all maritime container cargo to be loaded on a foreign trading vessel intended for entry into a port in Japan. The only current exemptions include Break-bulk cargo, empty container shipments (SOC and COC), and maritime container cargo not to be discharged in Japan (Freight Remaining On Board; FROB).
3. Ocean AFR Data Elements
Japan’s Ocean AFR data elements are based on the WCO SAFE Framework and pull elements from both the ocean master and house bill of lading. There are requirements for detailed cargo descriptions, based on Harmonized System (HS) Code at the 6-digit level.
While more data elements are required, the quality of the information transmitted will also be of key importance. For example, in the ‘Description of Goods’ field, it is no longer acceptable to simply state that a shipment contains “‘apparel”’. Instead, the field must be populated with a more detailed description, such as “Women’s knitted shirts, 100% cotton.” Additionally, some fields may require further party and sourcing information. Under the new AFR rules, for example, a consignee’s full address, telephone number and country code are required. Japan Customs has stated that incomplete filings may not be accepted.
4. Penalties for Non-Compliance
Japan Customs has noted that “penal provisions could be applied” and that cargo may not be unloaded “without the permission of discharge by Customs.” In addition, the agency has stated that those who do not submit cargo information may be “liable to imprisonment with labor for up to a maximum period of one year or a fine not exceeding five hundred thousand yen.”
5. How to File
Submissions from foreign ocean AFR filers cannot be made directly to Japan Customs. All foreign filings need to be made through service providers authorized by Nippon Automated Cargo and Port Consolidated System, Inc. (NACCS Center). For the list of service providers for Japan Advance Filing Rules authorized by NACCS Center to connect directly to NACCS, please visit to the NACCS Center’s website at http://www.naccscenter.com/afr/lsp.html. This is because the filing system must be located in Japan. The NACCS Center is responsible for import/export processes and customs-clearance services in Japan. It serves as an intermediary or ‘hub’ between the trade and Japan Customs.
6. What You Need to Do…
The data which needs to be included in the transmission is as follows:
• Shipper’s full style name and address
• Consignee’s full style name and address (unless to order)
• Notify party’s full style name and address (incl. telephone if consignee is to order)
• Container number
• Seal number
• Number of packages
• Cargo gross weight
• UN dangerous goods code for shipments containing hazardous goods
• Cargo description and HS code at a minimum of 6 digits
7. Helpful Educational Links…
(1) Japan Customs Link: http://www.customs.go.jp/english/summary/advance/index.htm
(2) NACCS Link: http://www.naccscenter.com/afr/
(3) CyberLogitec’s SmartLink: https://opussmartlink.com/si/index.do
* About CyberLogitec
CyberLogitec, an authorized service provider for Japan Ocean AFR compliance, provides a variety of flexible options to meet the needs of filers that run the whole gamut in terms of size and level of technical sophistication. CyberLogitec offers user-friendly solutions named SmartLink that can be readily accessed via the web and enterprise-class solutions that are pre-integrated into the shipment management and/or global regulatory compliance platforms which their customers are already using — making the process as seamless as possible. CyberLogitec can also help filers obtain a Reporter ID, a designation similar to a Standard Carrier Alpha Code (SCAC) in the United States. A Reporter ID is required to file a Japan Ocean AFR submission.
* Appendix — Summary of AFR
|Which shipments need to file?||Containerized shipments by sea to Japan. (AFR is applied at the last foreign port where cargo is loaded on a vessel heading for a port in Japan.)|
|Purpose of filing||Japan Customs will check shipment info before loading. If they consider a shipment is a threat, shipment will not be allowed to load onboard or unload to Japanese ports.|
|How to file?||Transmit shipment details electronically to Japan Customs.|
|When to file?||At least 72 hours before loading on board depending on each shipping lines.|
|What to file?||1. AHR (procedure to register advance cargo info): all B/L info, full cargo descriptions, and HSCODES of the most valuable or heaviest item.
2. ATD (procedure to report departure date and time): only shipping lines are required to file this.
|What happens if fail to file or file after the deadline?||1. Japan Customs will issue SPD notice.
2. Shipper must pay penalties, and ask Japan Customs for permission to discharge cargo. Then, filing must still be done.
3. If 2 is not done or Japan Customs does not give permission to discharge cargo, cargo will not be unloaded to Japanese ports. Shippers must pay penalties and pay arising charges to ship the cargo back.
|Can amend or delete manifest?||1. Before ATD is transmitted by shipping lines: Yes, can amend/ delete with a fee.
2. After ATD is transmitted by shipping lines: can amend/ delete only when Japan Customs issues HLD (hold), DNL (do not load), or DNU (do not unload) notice. Shippers also need to pay amendment fee.
|Who must file?||Shipping lines and NVOCCs (shippers are not required to file but have to provide to us info for filing before deadline)|
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