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The Bureau of Customs is temporarily suspending the imposition of penalties on freight forwarders and deconsolidators for late submission of cargo manifests
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OCOM Memo No. 61-2025 signed by Customs commissioner Ariel Nepomuceno cited “limitations” in the BOC’s electronic-to-mobile system as reason for the penalty suspension
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The suspension remains in force until the E2M system is able to, among others, handle volume of such submissions or transactions without error or system slowdown
The Bureau of Customs (BOC) is temporarily suspending the imposition of hefty penalties on freight forwarders and deconsolidators for the late submission of electronic consolidated cargo manifests (e-CCM).
Penalties range from P100,000 to P300,00 per bill of lading under Section 8.8 of Customs Administrative Order (CAO) No. 15-2020. This CAO contains BOC rules in the supervision and control over vessels and aircraft.
OCOM (Office of the Commissioner) Memo No. 61-2025 signed by Customs commissioner Ariel Nepomuceno dated September 24 and released on September 30 cited “limitations” in BOC’s Electronic-to-Mobile (E2M) system as reason for the suspension. Sources said this is related to the limited storage of the E2M.
“Delays in the submission of manifests caused by these system limitations are deemed justifiable technical problems under Section 4.10 thereof [CAO 15-2020] and shall not give rise to penalties,” the memo pointed out.
Under Section 4.10 of CAO 15-2020, technical problems encountered by the customs computer system is a justifiable cause for not penalizing late submission of electronic cargo manifest.
Consistent with Section 9 of CAO 15-2020, which provides for transitory application pending full implementation of a comprehensive cargo manifest and control system, the latest memo said the suspension will remain in force until BOC’s E2M System is able to perform the following:
- allow freight forwarders to electronically submit and store data in advance;
- automatically merge the submitted and stored data of freight forwarders with the aircraft’s or vessel’s data; and
- handle the volume of such submissions or transactions without error or system slowdown
The suspension of penalties had been initially implemented on March 14 through OCOM Memo No. 21-2025. The memo allowed freight forwarders to submit the advance manifest even without the corresponding master bill of lading (B/L) or master airway bill (MAWB).
READ: BOC order helps forwarders avoid penalties for late manifest submission
Freight forwarders normally have to wait for the carrier (airline or shipping line) to submit the master B/L/MAWB to the E2M System before they could submit their AWB/B/L. This situation has led to instances of late manifest submission.
Forwarders have long complained they bear the brunt of the penalties despite not having control over when carriers submit their MAWB/BL.
But due to technical difficulties, OCOM Memo 21-2025 was suspended only a few days into its implementation and was re-implemented in April. Freight forwarders, however, continued to pay for penalties despite the re-implementation of the memo, according to sources. – Roumina Pablo
