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The United Portusers Confederation of the Philippines supports the Bureau of Customs’ proposed new customs processing system but said its implementation should not result in higher fees or additional administrative burdens
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UPC said the CPS should first undergo regulatory impact assessment by the Anti-Red Tape Authority before implementation
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The cost of modernization should also be subsidized by government as part of its investment in trade facilitation, the group added
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Any sudden increases in customs-related fees can affect logistics planning, financial projections, and “ultimately the competitiveness of Philippine trade operations,” UPC noted
The United Portusers Confederation of the Philippines, Inc. (UPC) supports the Bureau of Customs’ (BOC) proposed new customs processing system (CPS) but said its implementation should not result in higher fees or additional administrative burdens for port stakeholders.
In a position paper, UPC recommended maintaining the status quo in fee structure under BOC’s Electronic-to-Mobile (E2M) System. “The proposed CPS, being a replacement or enhancement of the existing E2M system, should not be used as a mechanism to introduce higher fees or new charges without clear legal and economic justification, proper cost-benefit assessment, and full stakeholder consultation,” it reasoned.
The process should also first undergo regulatory impact assessment (RIA) by by Anti-Red Tape Authority (ARTA), said the group, an amalgamation of various industry associations.
BOC on January 23 conducted a public consultation on its proposed new CPS and its fees structure.
A joint venture composed of ADR Holding Corp., Ascent Solutions Philippines, Inc., JAMC Holdings Corp., Omniprime Marketing, Inc., and Arcilla Margaroli Salazar Holding Inc. submitted an unsolicited proposal for a new CPS that will replace the E2M System, introduced in the early 2000s and is considered outdated.
The proposal was submitted as a public-private partnership (PPP) project with an estimated cost of P742.49 million. It will require a review by the BOC as user and an approval of its mother agency, the Department of Finance.
READ: P742.5M proposal for new customs processing system under review
According to the project profile posted in the PPP Center website, the CPS is designed to streamline and automate customs procedures, ensuring efficient, transparent, and compliant trade facilitation. Powered by artificial intelligence, the system includes key modules for managing customs declarations, risk assessment, payment processing, and other critical operations, providing a fully paperless trade environment that meets international standards.
UPC noted that current fees under the E2M System, such as the lodgement fee of BOC-accredited value-added service providers, “are already reflective of the cost of digital and administrative facilitation under the present system.” These fees, it said, include:
- Cargo Data Exchange Corp.’s P45 per entry, P18 per sea manifest, and P23 per air manifest
- E-Konek Pilipinas, Inc.’s P55 lodgment fee plus import fee (which varies by invoice value)
- GoFast’s P40 per container
“Any further increase or imposition of new fees in connection with the CPS would unduly burden the freight forwarding community, particularly at a time when businesses are still recovering from global disruptions and heightened operating costs,” the group pointed out.
It added that sudden increases in customs-related fees can affect logistics planning, financial projections, and “ultimately the competitiveness of Philippine trade operations.”
UPC pointed that in line with Republic Act (RA) No. 11032, otherwise known as the Ease of Doing Business and Efficient Government Service Delivery Act of 2018, any new regulation or system must not add undue regulatory burden or cost to stakeholders but rather, should simplify processes, enhance transparency, and reduce compliance costs.
Also in keeping with RA 11032, UPC said all proposed regulations and systems introduced by government agencies must undergo a RIA prior to implementation to ensure that such measures do not impose undue regulatory burdens on citizens and businesses.
The RIA process also promotes public participation and transparency, allowing affected stakeholders to meaningfully contribute to policy formulation.
“Accordingly, we respectfully submit that the proposed CPS must first undergo full Regulatory Impact Assessment by ARTA before any implementation or imposition of new procedures and fees, in compliance with the principles of the Ease of Doing Business Act and sound regulatory governance,” UPC said.
The group noted that modernization of customs systems “should primarily aim to streamline processes and improve service delivery.”
“Efficiency should be measured by faster clearance times, transparency, and improved system reliability — not by increased costs to stakeholders,” UPC said.
Should the new CPS proceed, UPC said “any cost associated with the development, deployment, or maintenance of the new system should be borne or subsidized by the government, consistent with the principle that modernization initiatives are public investments intended to benefit the entire trading community and enhance national competitiveness.”
The group said this approach recognizes that the private sector, particularly port users, “already bears significant operating expenses under the current customs framework.”
“It would therefore be equitable and in keeping with sound public policy for the government to shoulder or subsidize the costs of implementing a system that primarily serves a regulatory and facilitative function.”
Moreover, UPC said introducing new or higher fees under the new CPS would contradict its modernization objectives and would run counter to the government’s broader thrust to promote competitiveness and reduce the cost of doing business in the Philippines.
READ: BOC commits to sustaining automation initiatives
“In all, UPC supports the Bureau of Customs in its pursuit of digital transformation. However, we respectfully emphasize that modernization must not lead to increased costs, reduced predictability, or additional administrative burdens for legitimate port users,” the group said. — Roumina Pablo
