Document

Report
Air-Cargo: Suggestions for
Efficiency Enhancement
10 July 2013
Udyog Bhawan: New Delhi
© Confederation of Indian Industry
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Waiting Time of 3-4 hours plus (in truck que and ramp que), due
to Manual Ramp Operations and Lack of IT integration in
processes
Current Process:
Presentation of physical Annexure C document, followed by manual entry of details
into system, and assignment of Examining Officer (EO). This is followed by manual
carting of export cargo into cargo terminal.
Suggested Changes
EDI submission of Annexure C information online with reference to HAWB and MAWB.
RFID scan enabled entry registration process at terminal ramp. EO assigned
automatically post-scan
Export RMS allows segregation of shipments into those requiring physical examination
and those not at the RFID scan stage. Carting into separate zones based on this
segregation
Mechanical Carting: Mandating Terminal Operator in Major Airports to use ramp-carts
© Confederation of Indian Industry
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Time to taken to complete customs procedures can be reduce by half as well
as reduce the pressure on Customs officials through greater use of IT,
allowing EDI to accept pdf scanned documents, separation of document
based assessment and physical examination functions, and use of CCTV for
record keeping
Current Process
-Physical documents (invoice, Declarations etc) submitted to EO. EO takes a call on physical
examination. Once he gets a break from document assessment, makes a round of terminal for
physical examination. Sometimes second physical examination is mandated
Suggested Change
 All documents (incl scanned pdf versions of supporting documents such as invoice, packing list
etc) are submitted on EDI, and can be viewed and assessed by EO. EO can then take a call on
whether further physical examination is required.
 If physical examination is required, system automatically assigns a EO on the floor (on physical
examination duty), and message alert is send to the assigned officer.
 Physical examination is undertaken in a zone fitted with CCTV cameras, whose footage can be
retained for a specific amount of time. Second physical examination is dispensed with.
 Once physical examination EO (on floor duty) sends back confirmation to EO on document
assessment duty, and LEO is given automatically
© Confederation of Indian Industry
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EPCG/Chapter 3 scheme exports need special assessment that
adds to dwell time
Current Process
-Physical submission of documents () to incentive cell. Work usually starts after 1 PM.
Assessment and clearances takes up to 2 hours best case scenario. If marked for physical
examination process can take much longer. This ensures that cargo often does not get
opportunity to enter terminal until next day (due to congestion). Adds 1 day to the dwell time
on average. Since shipment has not been brought into the terminal and carted in, this dwell
time is not considered as an official ‘cargo dwell time’.
Suggested Change
 All documents (incl scanned pdf versions of supporting documents such as invoice, packing
list etc) are submitted on EDI, and can be viewed and assessed by EO in incentive cell prior to
arrival. Physical submission is dispensed with.
 All scheme imports are automatically send to the ‘physical inspection’ zone post RFID entry
 System automatically assigns a EO on the floor (on physical examination duty), and message
alert is send to the assigned officer.
 Physical examination is undertaken in a zone fitted with CCTV cameras, whose footage can
be retained for a specific amount of time. Second physical examination is dispensed with.
 Once physical examination EO (on floor duty) sends back confirmation to EO on document
assessment duty, and LEO is given automatically
© Confederation of Indian Industry
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CHANGES IN THE GRANTING OF
NOC PROCESS
© Confederation of Indian Industry
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Fine Tuning the NOC Granting Process: Introduction of Prior Submission,
Acceptance of PDF documents online and direct response to (message
exchange) to the EDI system
Current Process
-The current (both inbound and outbound) process involves physical submission of
documents (as listed by agency) post arrival at the airport/port to concerned agency
responsible for the specific NOC
-After processing of such documents, samples might be drawn if deemed necessary by
the agency. In case no samples are drawn, NOC is granted. In case samples are drawn,
NOC is granted post laboratory testing analysis results.
Suggested Change
Prior Submission of Documents Online
Clearance Based on Message Exchange with EDI
Minimum Service Standards
Introduction of RMS
© Confederation of Indian Industry
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EXEMPTIONS FOR REQUIREMENT OF NOC FOR SPECIFIC TYPES
OF SHIPMENT
•
Imports and Exports of SEZ/FTWZs units should not be subject to customs
compulsory requirements (CCR) related to compliance with allied agencies
•
Exemption of all samples AND shipments coming for Research and Development
Services
•
Exemption for the requirement for NOC for bulk drug export shipments
© Confederation of Indian Industry
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Trade Facilitation for SEZs and FTWZs
Imports bound for SEZ/FTWZs Cleared on Arrival Facility using CCTV enabled trucks
Cleared
on arrival based on prior declaration, with no requirement for physical
inspection or checks at the point of entry (port or airport).
A
basic message exchange system in Customs ICEGATE should be able to transmit this
information to SEZOnline
CCTV
enabled truck movement between entry port and SEZ/FTWZ (or bonded truck)
All
checks would be conducted at the SEZ/FTWZ entry point, where shipments would
be tallied with the information provided by SEZ/FTWZ importer to ICEGATE (observable
through message exchange with SEZonline, as suggested)
Officials
can also check CCTV footage in case of doubt or systemically ask for such
CCTV footage on a random basis based on some RMS criteria
© Confederation of Indian Industry
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Doing away with the requirement of customs escort

Some customs field formations still insist on customs escort for truck movement
between port of entry and SEZ/FTWZ. This adds to costs (and also delays, due to
lack of availability of officers)

It is suggested that such requirements are done away with. Instead, customs can
over-time insist that trucks doing sealed movement of goods (container sealed,
sealed packages) are CCTV enabled, with the provision to be able to see CCTV
footage on demand
© Confederation of Indian Industry
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Customs Related Suggestions
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Export promotion copy is required to be signed by the
proper officer despite introduction of EDI, which creates
delays


Removing the need for EP copy or ARE1 certification by proper officer where
Export shipment is cleared under EDI mode
EDI message to be exchanged or print out to be used.
Requirement that physical records be maintained for 5 years
•This requirement results in paperwork build-up despite the fact that there is EDI
which has a direct impact on environment
•EDI was introduced with the intention of reducing paperwork, ease of record
maintenance and retrieval to government, improving transparency and trade
enablement.
• It is suggested that the need for maintaining import and export shipment related
physical records by the agents is removed, and customs accepts electronically stored
versions (pdf scanned images) of the same
© Confederation of Indian Industry
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Customs EDI enabled to accept pdf images as submission of
proof

Customs EDI should be enabled to accept pdf images of licenses, invoice,
declarations etc so that the requirement for ANY PHYSICAL PAPER copy is
dispensed with

RMS based checks introduced. Heavy NON-NEGOTIABLE penalty in any case where
pdf scanned documents are not the same as the original hard copy
© Confederation of Indian Industry
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Delegation of powers to ensure quicker clearance time and
reduce burden on senior level officers

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There are delays when file move beyond the Assistant / Deputy Commissioner levels
due to the busty work schedule and responsibilities of the higher level officers
Delays also happen at assessment level where Assistant / Deputy Commissioner
counter signature is required due to assessable value being greater then INR 1 lakhs
or 1st check order is required or such other cases
It is requested to the below change be introduced considering the increasing value of
products and exchange rates for all situations except adjudication
Import:
a. Assessing / Officer on duty: Value
below INR 5 lakhs
b. AC / DC: No limit
Export: Free, NFEI& Scheme shipping bill
a. Assessing / Officer on duty: Value below INR
5 lakhs
b.AC / DC: No limit
Export: Drawback shipping bill
a. Assessing / Officer on duty: Drawback Value
below INR 1 lakhs
b. AC / DC: No limit
© Confederation of Indian Industry
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Shortage of staff in particular locations leading to delays in
assessment

Currently assessment is done locally in each customs station. Shortage of
staff especially during holiday season impacts the trade and creates
difficulties for the officers and trade

It is our suggestion that a common assessment pool be introduced on all
India basis on various levels required for assessment

Under this system, while officers may continue to be located in different
locations physically, they can be available to assess files submitted at any
port/airport/point of entry. The file can be routed to the login officer who
is free and has the capability to assess the shipment for Import and
export. (This is possible due to the fact that all customs are connected via
EDI 1.5 version).
© Confederation of Indian Industry
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Daily duty allocation of customs officials (Exports & Imports)

Currently the deployment of customs officials in the warehouses is
manually done daily to provide for warehouse wise rotation.

Then manual roster is circulated daily for necessary internal approvals,
which leads to increased processing time and delays in the actual start of
the daily operations in the morning

The rostering can move to a system generated roster which can provide all
the necessary controls and the officers can start work immediately on
arrival on the shift and not wait for the manual roster to be provided
© Confederation of Indian Industry
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Optimum Utilization of EDI
IEC usage security and Data Transparency
(Exports & Imports)

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Currently there is no mechanism for an Importer or
exporter to get information on the unauthorized usage of
their IEC.
No options to get reports on monthly / regular intervals
with reference to imports/export done in each clearance
location by importer /exporter or the statement of usage of
their licenses, bonds, etc.
There is an option to Track shipments on ICEGATE.
It is suggested that IEC Holder receives



Import / Export alerts as & when a document is filed on EDI
Monthly report of Bill or entry / Shipping bill filed
Monthly report of licenses / bonds used with closing balance
Enabling Repair Return shipments

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


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Currently the EDI does not identity repair return shipment .
The onus of ensuring that the Customs examination report
mentions about “identity being established” lies with the
exporter despite the fact that they have no control on the report
The repair return business has huge business opportunity and
the same should be encouraged by making simpler process &
EDI doing cross reference
It is suggested that the EDI should have “Repair Return” as a
shipping bill type.
Where there is no objection, it must be considered re-export
has been done. Where there is negative report, Broker /
Exporter approval received
Exporter should get copy of examination report with Shipping
bill
Mechanism for automatic closure of bond which get executed
at time of export where import BOE is mentioned in S/Bill
Smooth Multi Port clearance
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Enabling logistics convenience will enable the Trade
Current day Exporters procure material from multiple locations
due to multiple manufacturing set up / vendor set up
Presently an exporter has to register self in each of the port
from where export / import propose to be done
EOU have to undergo registration process in every proposed
port of clearance
It is suggested that there should be automatic registration for
EOU / SEZ / FTWZ as soon as the set up formalities is
completed &
Similarly where IEC is issued the information should get
reflected in EDI automatically without the need for any
registration. Additional information filed in one port should get
reflected in every port
EDI for Trade convenience

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Basic principal of EDI is avoid submission same data to
various authorities transit points
The Export trade can be enabled by starting a paperless
environment where shipping bill filed become the
document of reference without the need for physical copy
of Invoice & various other declarations
All Chapter 3 licenses should be online to enable export
import from any port without the need for Transfer release
advice or origin copy of license ( more secure)
Bond executed in any one port or drawback account
opened in one port should be valid for clearances in other
ports
License issued by any allied agency should get reflected
in EDI so that license debiting takes place on line &
clearance can be done from any location
Thank You
© Confederation of Indian Industry
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