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The Bureau of Customs has issued new rules simplifying the arming of electronic customs seals on export shipments from customs bonded warehouses under the Electronic Tracking of Containerized Cargoes System, expanding the list of personnel authorized to perform the procedure beyond BOC warehousemen
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Under Assessment and Operations Coordinating Group Memo No. 98-2026, the CBW operator’s own accredited member-exporter — through a designated authorized representative — may now arm the electronic customs seal even without a BOC officer physically present, a significant departure from the previous requirement that only BOC personnel or the E-TRACC service provider could do so
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The new memo also streamlines the booking and delivery process for the electronic customs seal, requiring delivery within 24 hours of booking and setting a two-day limit on unused seals before they must be returned
The Bureau of Customs (BOC) has streamlined procedures for arming electronic customs seals (ECS) on export shipments from customs bonded warehouses (CBWs), expanding who is authorized to perform the process and simplifying the steps involved — changes that should reduce delays and give exporters more flexibility in managing their shipments.
The new rules are contained in Assessment and Operations Coordinating Group (AOCG) Memorandum No. 98-2026, issued pursuant to Section 10.9 of Customs Memorandum Order (CMO) No. 04-2020, which established the Electronic Tracking of Containerized Cargoes (E-TRACC) System.
E-TRACC is a web-based system launched in 2020 that tracks the inland movement of containerized cargo during transit and transfer to other customs territories and facilities. It allows BOC to track, monitor, and audit the location and condition of cargoes in real time, and to receive alerts when cargo is diverted or tampered with.
Central to E-TRACC is the electronic customs seal — a GPS-enabled device that physically locks a container and transmits its location continuously. Before a sealed container can move from a CBW to the port of loading, the ECS must be armed (activated and affixed). Under the old rules, only BOC’s assigned customs warehouseman could arm the ECS, with the E-TRACC service provider, Ascent Solutions Philippines Inc., allowed to assist only in cases of inadequate BOC personnel and only under the supervision of the Piers and Inspection Division or its equivalent. The CBW operator and the exporter had no direct role in the arming process.
What changed under AOCG memo No. 98-2026
The new memo significantly expands who is authorized to arm the ECS. Three categories of personnel are now explicitly authorized:
- Warehousemen and other authorized BOC personnel (the primary responsible officers, as before)
- The E-TRACC service provider, Ascent Solutions Philippines Inc.
- An authorized representative from the CBW operator’s accredited member-exporter
This third category is the key change. Under the previous rules — specifically AOCG Memo No. 493-2021 on E-TRACC implementation for economic zones and AOCG Memo No. 45-2022 on CBW imports and exports — only BOC personnel could arm the ECS, with the service provider as a fallback. The new memo now allows the exporter’s own designated representative to arm the seal, even without BOC personnel physically present, provided the representative has been formally authorized and registered in the E-TRACC booking system through an affidavit of undertaking.
This is a meaningful operational shift. Previously, the requirement for a BOC officer to be on-site for ECS arming could create bottlenecks — particularly outside regular office hours, when overtime pay, transportation, and meal allowances had to be arranged. Under the new rules, the exporter’s own authorized personnel can handle arming directly, removing that dependency.
Other simplifications in the new memo include:
- CBWs must now book ECS devices through the ECS/GPS Export Device requisition module on the E-TRACC System website (https://www.ecms.ph), with the service provider required to deliver the physical ECS within 24 hours of booking.
- Any ECS not used within two days of delivery must be returned to the service provider — a clear, time-bound rule that prevents unused devices from lingering at warehouses.
- Requests for ECS arming by the service provider must be made at least 24 hours before the actual arming, while requests to BOC personnel must be made at least three days before the container stuffing date.
- Authorization by the district collector for any BOC employee to arm an ECS is now valid for six months and renewable, giving ports a cleaner administrative framework.
Accountability framework unchanged
Despite the expanded roster of authorized armers, accountability remains strict. Member-exporters must execute an affidavit of undertaking designating their authorized officer and holding both the officer and the exporter liable for any violations under the E-TRACC System. The CBW operator’s general warehousing bond — which CBWs are already required to maintain — will cover any liabilities arising from infractions or violations, without prejudice to civil, criminal, or administrative penalties under the Customs Modernization and Tariff Act.
The new memo is part of BOC’s ongoing efforts to upgrade and modernize the E-TRACC System. In June, the AOCG also announced the deployment of the new Automated Track-Trace-Transfer System (AT3S) ECS, which features improved accuracy and reliability, with rollout scheduled from June through July.
Separately, BOC issued CMO No. 04-2026 last May, exempting Authorized Economic Operator (AEO) Program Level 1 members that are also registered with investment promotion agencies from E-TRACC System implementation — positioning the exemption as an incentive for companies accredited under the AEO Program. — Roumina Pablo
