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The Association of International Shipping Lines is not in favor of the Bureau of Customs’ proposed In-Transit Asset Management and Supervision System
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The association said the system falls short of its objective, adds layers of procedures, and constitutes regulatory overreach
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ITAMSS is designed to allow BOC and truck operators to track, monitor, and audit location and condition of empty containers
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The system’s coverage is limited and does not meet the objective set by a customs order related to monitoring dwell time of foreign containers, AISL said
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The proposed ITAMSS booking fee of P850 per container is “simply unacceptable” and will translate to P2.6 billion annually of additional costs to the logistics chain, it added
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Instead, AISL recommends revisiting discussions on the proposed Automated Container Movement Monitoring System, an end-to-end solution at no cost to government as well as to the transacting public
The Association of International Shipping Lines (AISL) is not in favor of the Bureau of Customs’ (BOC) proposed In-Transit Asset Management and Supervision System (ITAMSS), saying it falls short of its objective, adds layers of procedures, and constitutes regulatory overreach.
In a position paper submitted to BOC dated March 17, AISL said ITAMSS will be “ineffective and will not efficiently serve the purpose” that BOC aims to achieve due to several reasons.
BOC in late February published a draft customs memorandum order implementing ITAMMS, a secure and interactive system that will allow BOC and truck operators to track, monitor, and audit the location and condition of empty containers. Stakeholders were given time to submit their positions on the proposed system.
ITAMSS will be a component subset of the import monitoring program of BOC and implements – particularly for empty containers – Customs Administrative Order (CAO) No. 08-2019, which provides the policies on the admission, movement, and re-exportation of containers at seaports.
The proposed CMO comes as BOC said it is looking into tighter supervision and regulation of empty container depots via the mandatory use of an automated inventory management system. This system will allow BOC to strictly monitor and generate real-time and accurate information capacity of empty container depots.
This is one of the measures meant to address high yard utilization – especially for reefers – in Manila international terminals and empty container depots.
AISL, which represents foreign container shipping lines and agents calling the Philippines, said ITAMSS’ coverage is limited and does not meet the objective set by CAO No. 08-2019 in monitoring dwell time of foreign containers.
AISL said ITAMSS “is more concerned in tracking the movement of the empty containers from the importer’s warehouse until its return to the container yard /depot.”
It explained: “Under its limited coverage, monitoring under ITAMSS takes place only AFTER the container has been discharged from the carrying vessel, undergone the necessary Customs clearance, settled the necessary shipping and terminal fees, released from the port and delivered to the consignee’s/importer’s warehouse. How much time was left in the 90-day dwell time period becomes a huge problem both for the Bureau of Customs and shipping lines.”
Under CAO 08-2019, all containers, whether loaded or empty, should be re-exported within 90 days from the date of discharge of the last package from the carrying vessel.
On the ITAMMS requirement for the electronic customs seal (ECS) as a monitoring tool for the movement of empty containers from the origin, AISL said this “failed to take into account that, for reasons of economy and cost efficiency, 70% of empty containers are transported from the importer’s warehouse direct to the terminal (MICT [Manila International Container Terminal /South Harbor) while only 30% are transferred to outside container yard/depot.”
ECS is a GPS (global positioning system)-enabled sealing device or lock that physically secures a cargo and provides real-time information on its location. It is in use for BOC’s Electronic Tracking of Containerized Cargoes.
“With only 30% of the empty containers practically being monitored by ITAMSS, its effectiveness as a monitoring tool even more becomes highly suspect,” AISL noted.
Moreover, AISL claims there is no justification to utilize a GPS device to track a container in real time.
The group said if the objective is to make sure there is space at the empty container depot, and that the depot will accept the container, “all that is needed is a depot inventory system with allocation for containers based on Delivery Orders and Appointments.”
AISL said delivery orders with specific return destinations will provide depots with the data for space allocation, and a confirmed slot can be allocated when the appointment is made.
Stakeholders have earlier noted that despite a specific container depot indicated in the delivery order, there are still depots that will not accept the empty container because it is full or due to some other reason.
AISL said ITAMSS also adds layers of procedural steps before truck dispatch that amounts to “logistics inefficiency that could only hamper the movement of trucks carrying empty containers.”
It said the proposed procedure of booking, assigning an ECS, delivering an ECS to the importer’s premises, the recording of a video by the ITAMSS authorized personnel to show that the container is empty, among others, “will necessarily require the trucker to wait a long time which adds significantly to logistics inefficiency.”
“This new handling steps before dispatch will seriously impair the truck’s turnaround time not to mention that, a material delay in the return of the empty container will affect the planned date and arrival of the empty container to the container yard/depot,” AISL said.
Moreover, the group said appointment booking systems for empty container returns are already available from other service providers, such as the GoFAST System and the Alliance of Container Yard Operators of the Philippines’ Simply Book.
With the surge of fuel prices and an energy crisis looming in the horizon due to the Middle East conflict, AISL said the proposed ITAMSS booking fee of P850 per container “is simply unacceptable.”
The organization said this translates to P2.6 billion annually of additional costs to the logistics chain that the importing community and industries cannot absorb on top of the extreme financial volatility presently experienced globally.
AISL said activities involved under the ITAMSS “are purely operational in nature as it clearly covers a series of commercial logistics activity that does not directly impact Customs control or revenue protection.
“It can only constitute regulatory overreach. Its provisions are tilted more for the benefit of truckers rather than the interest of shipping lines who owns the containers,” the group added.
AISL also said the ITAMSS framework appears to be “biased towards the truckers and against shipping lines who own the containers.”
Effectively, ITAMSS, the association said “merely serves as a tool to address the problems of the truckers in the return of empty containers which are usually experienced during the “ber” months and post-holiday backlog (Jan-Feb), generally considered as a seasonal phenomenon.” The group claims the system “is not really a system designed to implement the provisions of CAO No.08-2019 in monitoring the dwell time period of foreign containers at the seaports.”
AISL instead pointed to the need for BOC to revisit the proposed Automated Container Movement Monitoring System (ACMMS), the subject of a Memorandum of Agreement on Data Sharing between BOC and AISL in August 2023. The ACMMS is an end-to-end solution at no cost to the government as well as to the transacting public, and also seeks to implement the provision of CAO No.08-2019.
AISL said discussion on the implementing operational guidelines of the ACMMS started right after the signing of the MOA in 2023 but failed to progress despite AISL efforts to finalize the guidelines preparatory to implementation.
The association recommends revisiting discussions on ACMMS, saying it addresses the need of BOC to monitor in-country dwell time and container inventory at both the terminals, depots and in-circulation, and features an appointment system that guarantees space allocation at the depots. – Roumina Pablo
