Canada: Clarifying proof-of-report requirements for exporters and carriers

February 12, 2020

The Canada Border Services Agency issued a release to clarify proof-of report requirements for exporters and carriers.

Customs Notice 20-03 (10 February 2020) explains the following:

  • The new Canadian Export Reporting System (CERS) introduces a new proof-of-report format and removes a gap that allows the proof-of-report number to be generated before an export declaration has been submitted. This guidance is intended to clarify exporter and carrier obligations related to the proof-of-report and offer guidance on how to complete an export declaration in three common exportation scenarios.

  • The proof-of-report number indicates that goods to be exported have been reported to the Canada Border Services Agency.

  • Carriers or customs service providers who are Memorandum of Understanding (MOU) participants must obtain the proof-of-report number from the exporter before the goods leave Canada. The exporter is not obliged to provide the MOU participant with a copy of the export declaration.

  • The proof-of-report format for each reporting method can be found in paragraph 45 and in Apprendix D of Memorandum D20-1-1 and paragraph 11 of Memorandum D3-1-8. In addition to the formats listed in these memoranda, exporters may also provide carriers with the CERS proof-of-report, which uses the following format: Exporter’s Authorization ID (Format: AA####) + Submission Date (Format: YYYYMMDD) + Sequential Number between 1 to 99999999999.

  • Currently, the proof-of-report number can be generated by the Canadian Automated Export Declaration (CAED) system prior to submitting an export declaration by saving a draft of the report. Although the number is available prior to submitting the export declaration, an exporter is required to submit the export declaration before providing the proof-of-report number to the carrier.

  • CERS will only generate a proof-of-report number after the export declaration has been successfully submitted.

  • The Canada Border Services Agency is aware that the exporting carrier occasionally obtains the proof-of-report before the export declaration has been submitted in order to provide the exporter a “unique carrier-assigned code”. This practice has originated from some carriers hardcoding their system to require the proof-of-report before generating a Cargo Control Number (CCN).

  • The “unique carrier-assigned code” on an export declaration must enable a carrier or warehouse operator to locate and present the goods to the agency for examination at any time prior to the goods leaving Canada. It is an alphanumeric sequence that must be 21 characters or less and cannot have been previously used within the calendar year. It does not need to be the CCN.

  • Further guidance on completing the “unique carrier-assigned code” is provided below for three exportation scenarios:
    • Goods are exported from Canada to a non-U.S. destination: The user enters the “unique carrier-assigned code” provided by the exporting carrier.

    • Goods are exported from Canada to the United States and proceed to a non-U.S. destination with a different carrier: The user completes the “unique carrier-assigned code” with information related to the carrier departing the United States. Other carrier information on the export declaration should relate to the carrier transporting the goods from Canada.

    • Goods are exported from Canada to a non-U.S. destination but the “unique carrier-assigned code” cannot be generated without a proof-of-report number: In this scenario, the carrier was previously obtaining the proof-of-report from the exporter or customs service provider before the goods were reported. This will no longer be possible when CAED is decommissioned.

Carriers unable to generate a “unique carrier-assigned code” without the proof-of-report number may instruct exporters to enter an identifier that can be used by carriers and warehouse operators to locate and present the goods to the agency for examination at any time prior to the goods leaving Canada. For example, a carrier may ask an exporter to use one of the following identifiers: trailer #, parcel #, container #, railcar # or equipment #.

The exporter would subsequently complete the “carrier-assigned assigned code” by adding the date of exit to this identifier. If multiple shipments are associated to the same identifier, the “unique carrier assigned code” would also need to number the shipments related to the identifier to make the code unique.

For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094

Irina Vaysfeld
T: 212-872-2973

Amie Ahanchian
T: 202-533-3247

Christopher Young
T: 312-665-3229

Gisele Belotto
Managing Director
T: 305-913-2779

George Zaharatos
T: 404-222-3292

Andy Doornaert
Managing Director
T: 313-230-3080

Jessica Libby
Managing Director
T: 612-305-5533

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