Electronic Sealing of Containers
Electronic Sealing of Containers
Gone are the days where a jurisdictional officer had to supervise the stuffing of export cargo. The Central Board of Excise and Customs (CBEC) has introduced a concept which enables the exporters to self-seal their containers using electronic seals. Implementation of these measures shall reduce the transportation cost as exporters no longer liable for MOT (Merchant Overtime) charges with respect to the supervision, combined with the fact that the time taken for moving the goods shall also reduce significantly. The initiative will be processed through RFID (Radio Frequency Identification) e-seal. This article is a brief account on the various pre-requisites pertaining to the recently launched system of electronic sealing of containers by the CBEC.
An entity should adopt the use of Electronic sealing of containers only for a fully loaded container sealed at an approved premise. All containers sealed electronically should avail prior approval from the authorized exporter. Exporters who were availing ceiling at the factory premises under the previous system of supervision automatically qualify for electronic sealing of containers. Further, exporters availing supervised sealing for the containers can start electronic sealing of containers automatically without any approval or permission from the jurisdictional commissioner.
Also, entities with prior approval for Authorized Economic Operator (AEO) status can electronically self seal containers regardless of whether they were involved in self-sealing or supervised sealing. Finally, all exporters having GST registration and filing GST returns can start electronic sealing of containers after obtaining approval from the respective jurisdictional Commissioner.
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GST Registration and Return Filing
Only exporters who have GST registration and filing GST returns can bring export goods to a CPS/ICD for stuffing and sealing of container or electronically seal containers. Further, GST registration is now mandatory for importing goods in India. Hence, its best for those involved in import or export business to obtain GST registration at the outset.
Procedure for Electronic Sealing of Containers
To seal the container electronically, all the eligible exporters should make sure the containers remain fully loaded. The exporters may exclude availing supervision from the customs officer, if the containers sealed electronically and fully loaded. If a full container load is received at a port or ICD with electronic self-sealing RFID, then it would be deemed to be the equivalent of a container sealed under the supervision of an Officer.
To receive permission from the jurisdictional Commissioner of Customs, the export goods should accommodate sensitive temperature without sterile. The facility at the port of export should contain proper temperature controlled examination features. After verifying these storage facilities with respect to the stuffing and sealing the export goods, the officer shall provide the permission for electronic sealing. However, after receiving the permission for electronic sealing for containers for export goods, the permission shall stay active. The permission shall become non-available only if the authorized officer notices non-compliance to the law, rules or failed to practice the regulations provided by the Department.
For Reefer Cargo
The exporter should request for supervisor at the Customs office atleast 24 hours before stuffing of reefer containers. The exporter should provide a detailed list including the nature of the goods and temperature maintained for the goods.After verifying the documents, the Customs office shall then appoint officers to supervise the examination, stuffing and sealing of the reefer containers
After examining the reefer containers and ensuring that the exporter met the parameter in stuffing the goods with proper storage and with required temperature, the officer shall then seal the containers with RFID e-seal. The officer shall also collect all the details related to the export and forward the details to the jurisdictional Commissioner of Customs. The exporter should upload all the details as provided by the supervisor, online.
The RMCC shall take necessary steps ensure that the sealed containers remain intact and not subjected at the port of export. The jurisdictional Commissioner of Customs shall inform the details of exports to RMCC on a monthly basis.
Full containers brought to ports without RFID e-seals would be taken to a CFS or allowed direct port entry and subject to usual RMS treatment. Similarly, Full Containers Loads arriving at ICDs, without RFID e-seals, will be subject to usual risk management parameters. Finally, in case of good reasons or intelligence to warrant inspection or if the electronic seals are tampered, then the containers would be subject to the normal processing with supervision.
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Intimation of Details
The jurisdictional customs officer shall no longer supervise, however, all the concerned exporters must duly inform the related to the details of premises and about the movements of and goods loaded in the container. An exporter who intends to pursue electronic sealing should inform the jurisdictional Customs Officer at the rank of Superintendent or Appraiser of Customs at-least 15 days before the first planned involvement of the consignment. The Jurisdictional Superintendent or Inspector of Customs will conduct an inspection on the premises to validate its viability and then submit a report of the same to the Deputy/Assistant Commissioner of Customs, who in-turn will forward the proposal to the Principal Commissioner/Commissioner of Customs. The Principal Commissioner/ Commissioner of Customs is vested with the rights of granting permission for electronic sealing.
After receiving the permission, the exporter must furnish all the required details and provide as an intimation to the jurisdictional Superintendent of Customs prior to each session of electronic sealing. On the other hand, if the report of the inspection conducted by the concerned authority is not satisfactory, the exporter needs to bring the goods to the CFS/ICD/port for sealing.
Clearance of Export Goods
Exporters who are intent on clearing export goods without the assistance of a customs broker i.e. on self-clearance, need to file the Shipping Bill under digital signature.
The exporter should seal the container with tamper-proof electronic seal of the specified standard. A unique number should be assigned to the Electronic Seal, which should be mentioned in the shipping bill. In addition to it, the exporter should specify details such as his/her name, IEC code, GSTIN number, description of the goods, tax invoice number, name of the authorized signatory and shipping bill number in the electronic seal.
Government Circular on Electronic Sealing of Containers
The government notification on electronic sealing of containers is reproduced below for reference:Electronic Sealing of Containers
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