DELIVERY ADDRESS ON FULL IMPORT DECLARATIONS

Friday, August 11, 2023

Thank you to all members who provided feedback to our member notice from Wednesday 9 August 2023. 

Freight & Trade Alliance (FTA) has shared this feedback with the Australian Border Force (ABF) and also the background of concerns raised over a 20 year period that multiple delivery address functionality was never built into the Integrated Cargo System (ICS). This was due to time and cost pressures for implementation prior to the final decommissioning of the legacy COMPILE system in 2006.
 
FTA also noted that industry and the ABF have collectively lived with this situation since ICS implementation in October 2005 with inconsistent guidelines on Full Import Declaration (FID) reporting requirements and without a concerted compliance focus in this area.
 
The inclusion of requirements in the latest Goods Compliance Update suggests that a compliance focus is to be ramped up.

As a part of the response to the ABF, FTA noted a need for guidelines on how to meet ABF compliance expectations in the various scenarios raised by members.

This included the scenario of rural destination consignments. A common practice is to report on the FID the place of FCL unpack (which may not be the ultimate consignee's address).

If this a metropolitan location, no rural tailgate inspection direction is required. If in this same scenario, the rural destination is reported on the FID, a direction would be generated. 

If industry were to adopt this practice, it would not achieve the intent of the Department of Agriculture Fisheries and Forestry (DAFF) policy and would be a significant burden on industry and DAFF resources.
 
FTA put forward the position that ideally the ICS should be enhanced to allow for multiple delivery addresses to be reported to accommodate all requirements.

In the absence of this, FTA noted the bottom-line a need for clear advice from government (combined position from both the ABF and DAFF) on reporting requirements.
 
Until there is an appropriate level of engagement with industry and an informed compliance program put in place, FTA has recommended a mortarium on any compliance activity be reinstated.
 
The ABF has committed to a follow-up meeting with FTA and importantly the inclusion of an invitation to key DAFF representatives.

We will keep members up to date on this important development.

Sal Milici - Licensed Customs Broker
General Manager Trade Policy & Operations - FTA / APSA
Chair – Container Cleanliness Working Group | Global Shippers Forum (GSF)  

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