Customs Notice N-418

Ottawa, December 14, 2001

Sufferance Warehouse Operators and the Release Notification System and Sufferance Warehouse Sub-Location Code

1. This notice concerns parties involved with importing commercial goods.  It is a follow-up to Customs Notice N-391, Sufferance Warehouse Operators and the Release Notification System, issued July 11, 2001, and Customs Proposal P-008, Sufferance Warehouse Sub-Location Code, issued April 24, 2001.

2. The following outlines changes to customs policies and procedures that will take effect July 1, 2002.

Release Notification System (RNS)

3. Sufferance warehouse operators may not release goods from their warehouse until they have received one of the following:

(a) the original or facsimile customs-stamped delivery authority copy of the cargo control document; or

(b) an RNS message received directly from the system as an RNS participant; or

(c) an RNS message received through the intermediary of a dedicated service provider such as a customs broker.

Note:  Following current policy and procedures, release notification for certain types of shipments, such as settlers effects and bulk mail, will continue to be paper based as they are not processed through the Accelerated Commercial Release Operations Support System (ACROSS) and no RNS is generated.

4. The service provider must submit to the Electronic Commerce Unit of the Client Services Division a letter of authorization obtained from the sufferance warehouse operator, to have the service provider's RNS profile updated to include the sufferance warehouse as its sub-client.  You can find a sample of the authorization letter and the contact information for the Electronic Commerce Unit in the RNS Participants Requirement Document that is available at the address in paragraph 12.

5. The service provider transmits the RNS message in hard copy format, i.e., by facsimile, to the sufferance warehouse operator for release and record-keeping purposes.

6. If customs officers find that goods were removed from a sufferance warehouse without proper release as defined in paragraph 3, the sufferance warehouse operator will be subject to a $1,000 penalty for the unlawful removal of goods from a sufferance warehouse under section 109 of the Customs Act.

Sub-Location Code

7. For commercial shipments, when the location of goods is a sufferance warehouse, the carrier, freight forwarder, or agent issuing the cargo control document must include the sub-location code of the sufferance warehouse when defining the location of the goods.  They may also include the text name of the sufferance warehouse.  The sub-location code is not mandatory when the carrier, freight forwarder, or agent is the sufferance warehouse operator.  Memorandum D3-1-1, Regulations Respecting the Importation, Transportation and Exportation of Goods, and the Appendix G, "Cargo Control Document Specifications," will be updated to include this requirement.

8. Where the carrier, freight forwarder, or agent has provided a sub-location code on the cargo control document, as described in paragraph 7, the importer/ broker transmitting the release information to ACROSS must include the sub-location code as a data element (refer to the ACROSS PRD).

9. Electronic release clients have requested that they be allowed the option to transmit a sub-location code for all release transactions.  As a result, when the location of goods is not a sufferance warehouse (i.e., a carrier break-bulk terminal located within the jurisdiction of a frontier customs office), the client may provide a sub-location code.  The code will be the last three digits of the customs office code, prefixed by a 9.

10. Sub-location codes, including those mentioned in paragraph 9, will be posted on the CCRA Web site under the Carrier and Cargo Policy Section at www.ccra.gc.ca/carrier.  Clients may also obtain the sub-location codes by contacting their local customs office or the Electronic Commerce Unit at the address found in paragraph 12.

Service Standards

11. A two-hour service standard will be implemented at customs offices for corrections to released transactions when the cargo control number, sub-location code, or container number has been entered incorrectly into ACROSS, and it directly affects the release of the goods.  The importers, their agent or sub-agent, as applicable, should request these changes in writing to the customs office of release using Form A48, R.M.D. Correction.  Requests will not be accepted by facsimile.  This form will be updated to include a sub-location code field.

Additional Information

12. To obtain a copy of the RNS participant's requirements document to become an RNS participant, please contact:

Electronic Commerce Unit
Client Services Division
Operational Policy and Coordination Directorate
15th floor, Sir Richard Scott Building
191 Laurier Avenue West
Ottawa ON  K1A 0L5

Telephone: (888) 957-7224
Facsimile: (613) 952-9979

13. For more information concerning this notice, please contact:

Mark Laramore
Release and Warehouse Programs
Import Process Division
Operational Policy and Coordination Directorate
8th floor, Sir Richard Scott Building
191 Laurier Avenue West
Ottawa ON  K1A 0L5

Telephone: (613) 952-0202
Facsimile: (613) 957-8630
Email:   mark.laramore@ccra-adrc.gc.ca