Automated Cargo Management (ACM) and the submission of electronic manifests became a reality this past week. A list of frequently asked questions (FAQ’s) and supporting information is attached to this email. The Association recommends that you ensure compliance with ACM.
AUTOMATED CARGO MANAGEMENT (ACM) SYSTEM
FREQUENTLY ASKED QUESTIONS (FAQ)
ELECTRONIC ROAD FREIGHT MANIFEST
• A “foreign road haulier” – i.e. a foreign road haulier not licensed to transport bonded cargo; and
• A “licensed remover of goods in bond not located in the Republic” (hereinafter referred to as a “foreign licensed remover of goods in bond”) – i.e. a foreign road haulier that is licensed to transport bonded cargo. In the case of a –
• “foreign road haulier”, legislation requires the road haulier to appoint a South African agent; and
• “foreign licensed remover of goods in bond”, legislation requires such a person to license as a “Remover of goods in bond”, as well as to appoint a “registered agent”. For ACM cargo reporting purposes the South African agent of a foreign road haulier, or the “registered agent” of a “foreign licensed remover of goods in bond” (as applicable), must also register their principal/agent relationship on forms DA8C and DA8C.01. What is a Road Freight Manifest? A Road Freight Manifest (RFM) is an electronic report of all the cargo carried on board a truck as compiled by the applicable road haulier. Each road haulier must assign a number to his RFM that is unique and not duplicated on another RFM before the expiry of a period of two (2) years after submission of the original RFM with such a number to the ACM system. The required structure of the RFM number for reporting purposes is – • Road Haulier code assigned by SARS – (AN 8);
• Road Freight Manifest Number assigned by the road haulier – (AN19) What is a Road Waybill? A Road Waybill is a document / invoice issued by a road haulier for the transportation of goods to a particular destination on board a truck and which serves as proof that the haulier has received the goods and has undertaken to transport the goods on the terms and conditions stated in the document. The relevant Road Waybill number(s) must also be reflected on the electronic RFM. Each road haulier must assign a number to his Road Waybill that is unique and not duplicated on any other Road Waybill before the expiry of a period of two (2) years after submission of the original Road Waybill with such a number to the ACM system. The suggestion for compilation of the road waybill number is – • Road Haulier code assigned by SARS – (AN 8);
• Road Waybill / invoice number assigned by the road haulier – (AN27) Who is the “responsible party”? The “responsible party” is the person on who the obligation rests to report cargo to the ACM system. • In the case of a South African road haulier, that road haulier is the responsible party.
• In the case of a “foreign licensed remover of goods in bond”, the “registered agent” appointed by that road haulier is the responsible party.
• In the case of a foreign road haulier, the South African agent appointed by that road haulier is the responsible party. Who is the “reporting party”? The “reporting party” is the person who actually transmits the electronic RFM to the ACM system. • In the case of a South African road haulier the reporting party can be – the road haulier himself (using either his own computer system or that of a service provider); or
an agent (e.g. another South African road haulier or a licensed clearing agent) appointed by the road haulier to submit his manifests to the ACM system on his behalf. • In the case of a foreign road haulier the reporting party can be –
the foreign road haulier himself; or
the agent appointed by the foreign road haulier; or
the “registered agent” appointed by the “foreign licensed remover of goods in bond” Whilst the manifest may be submitted by a “reporting party” as explained above, the “responsible party” retains overall liability (i.e. the “responsible party” is not absolved from the fulfilment of his obligations and remains liable for any act done by an agent on his behalf) Any agent appointed by a road haulier cannot “delegate” this agency to another party. What is meant by the term “truck”? A truck is a vehicle designed for the transport of goods and includes any self-propelled motor vehicle, tractor, articulated motor vehicle, a combination of motor vehicles coupled together, etc. What is the impact if I hire additional trucks or drivers? The transport equipment (i.e. whether self-owned, hired, leased, etc) utilised by a road haulier do not impact the reporting responsibility of that road haulier as explained above. The same applies to the on-board operator (i.e. the driver) of the truck.
It is the transport enterprise – e.g. “ABC Transport Logistics” that carries the reporting responsibility.
What happens if I use a sub-contractor? All road hauliers who is to cross a land border, irrespective of whether acting in a principal or a sub-contractor role apropos any particular haulage, is required to compile an electronic RFM in respect of the goods carried on their truck and to ensure that it is transmitted to the ACM system. Can there be multiple manifests in respect of a single truck (e.g. compiled by transport brokers)? No. Irrespective of the underlying commercial arrangements, cargo type (e.g. straight or consolidated), contractual arrangements or broker activities, for ACM reporting purposes there shall be only one manifest for a truck compiled by the road haulier who is to carry the goods across the land border on that truck and which is electronically submitted by that road haulier, or his agent, to the ACM system. Who must register? This again depends on whether the road haulier is South African or foreign. In respect of South African road hauliers – • All South African road hauliers carrying commercial cargo across land border posts must register with SARS as road hauliers for the purpose of reporting their cargo to the ACM system.• Application for registration as a road haulier must take place on forms DA8C and DA8C.01. Downloadable registration forms are available on – (http://www.sars.gov.za/home.asp?pid=558).
• If the application is successful, the person will be registered as a road haulier for ACM reporting purposes. SARS will either use an applicant’s existing customs code number, or assign a new code number where needed, when registering a person as a road haulier. • Any agent appointed by a South African road haulier as his or her “reporting party ” must complete forms DA8C and DA8C.01 and must supply the prescribed information regarding their principal(s). Please note –
Such agents may be any other South African road hauliers, licensed clearing agents or any other person approved by the Commissioner.
Registration as an agent does not constitute registration as a road haulier (e.g. a clearing agent does not become a road haulier merely because he or she is the reporting party for one).
Any change in agency arrangements previously registered in terms of the above procedure must be communicated to the Commissioner in the prescribed manner. In respect of foreign road hauliers • Any “foreign licensed remover of goods in bond” must–
Apply on form DA185 and associated annexure, form DA 185.4B6, to be licensed as a “Remover of Goods in Bond”; and
Nominate a “Registered Agent” on form DA 185.D • This “Registered Agent” must, for ACM cargo reporting purposes, also complete forms DA8C and DA8C.01 as agent and reflect the name of, and the customs code assigned to, his foreign principal following his or her licensing as a “Remover of Goods in Bond”. • The agent of any other foreign road haulier (i.e. a foreign road haulier not licensed as a “foreign licensed remover of goods in bond”) must, for ACM cargo reporting purposes, complete forms DA8C and DA8C.01 as agent and reflect the name(s) of his or her principals. These foreign road hauliers will then be assigned a “Foreign Road Haulier Code” by the ACM system that must be used for the purposes of electronically reporting the cargo carried across the border by that road haulier. How do I register to submit RFM’s to the ACM system? Registration is a two step process –
• First Step – Registration of a road haulier for purposes of the ACM system on forms DA 8C and DA8C.01 (dealt with above); and
• Second Step – Registration for the purpose of electronic communication with SARS on form DA185.4A6. Further details as to process, downloadable registration forms, communication channels, contact persons, etc can be found on the main ACM webpage – (http://www.sars.gov.za/home.asp?pid=558). What happens if some of the data on the manifest changes? Where a change occur to any data on a RFM already previously submitted to the ACM system (e.g. truck registration number changes), the sender must amend the manifest and resubmit it to the ACM system. By when must the manifest be submitted to the ACM system? This aspect is still under discussion with trade and this aspect will be communicated as soon as it is finalised. The proposal currently being considered is – In respect of goods to be exported from the Republic –
“The electronic Road Freight Manifest (RFM) may be communicated to the ACM system at any time after all the goods that are to cross the border on that truck has been physically loaded on the truck, provided that this is done not later than one hour before the truck reaches the border post or the control area of that border post” In respect of goods to be imported into the Republic –
“The electronic Road Freight Manifest (RFM) may be communicated to the ACM system at any time after all the goods that are to cross the border on that truck has been entered for customs clearance purposes, provided that the truck may not be processed through the border post before the RFM has been submitted” What happens to the current requirement to carry paper manifests in the truck and for use by neighbouring countries? The ACM requirements relate to the electronic reporting of road freight manifests and are, therefore, in addition to any current paper procedures. The current requirements relating to paper documents must, therefore, remain in place until further notice as any change thereto will take place in consultation with trade and our SACU / SADC neighbours. Furthermore, for purposes of the initial ACM roll-out a form DA 187 Road Freight Manifest (in respect of the movement of bonded cargo), or a trader-generated paper Road Manifest (non-bonded cargo), as applicable, must accompany the truck to the border. How will the RFM be implemented? The ACM implementation for road freight is scheduled to commence on 18 May 2012 and envisaged to be activated at the following offices:
• Kopfontein
• Ramatlabama
• Nerston
• Vioolsdrift
• Nakop
• Quachasneck
• Caledonspoort
• Mananga/Mahamba
• Jeppes Reef
• Van Rooyenshek
• Golela For the initial phase of the ACM implementation a hybrid solution will be employed –
• Road hauliers who have not submitted an electronic manifest to ACM will be processed in terms of the manual Service Manager process as is currently the case. SARS will compare clearance records against the goods listed on the paper manifest and, where any discrepancy exists, the necessary corrective measures will need to be performed by means of Vouchers of Correction (VOC’s).
• Road hauliers who have submitted an electronic manifest to ACM will be processed on the basis of the information contained in the electronic manifest. Provided that the information on the manifest is factually correct at arrival of the truck at the border, discrepancies on bills of entry appearing on that manifest regarding incorrect truck registration details will not require VOC’s from traders as a record of the correct information will be carried by SARS against the appropriate clearances. Important points to remember in the build-up to the implementation • Road Manifest Numbers must be unique per road haulier for a period of two years from issue – see above.
• A paper manifest must always accompany the driver of the vehicle – even where an electronic manifest has been submitted to ACM. This is needed for purposes of the gate-arrival process at the borer post.
• To avoid problems being experienced at the border, clearers must ensure that the manifest numbers on their customs declarations correspond to the manifest number on which the goods arrive at the border.
• For purposes of this initial implementation, SARS will not insist on multiple goods line reporting according to “package type”. It will be acceptable for cargo reporters to report the total number of packages for a particular LRN against a single “package type” using the most appropriate package type available. For example –
o LRN 12345678/GOL/20120510/128 consists of 10 boxes soft drinks and 10 cartons of biscuits and must be reported on an electronic Road Freight Manifest. Table 1: Correct ACM reporting
LRN | Goods Line Number | Number of Packages | Type of packages | Description |
| 12345678/GOL/20120510/128 | 1 | 10 | BX (Box) | soft drinks |
| 2 | 10 | CT (Carton) | biscuits |
Table 2: Acceptable reporting for the initial implementation
LRN | Goods Line Number | Number of Packages | Type of packages | Description |
| 12345678/GOL/20120510/128 | 1 | 20 | CT (Carton) | Foodstuffs |
• An ACM manifest is a report of commercial goods carried by a road haulier across a border and, as a result, it’s use is restricted to goods that are formally customs cleared and for which a LRN number has been issued. Where a truck carries both commercial goods, as well as goods for which formal customs clearance need not be made – i.e. DA 306 goods, the road haulier must also present the DA306 to the customs officer in order to account for all the goods loaded on the truck.
• Where a truck is en-route with cargo destined for multiple destinations outside the Republic, the field “Country of Destination” on the electronic manifest must contain the name of the first country located outside the Republic to which cargo is consigned during the truck’s journey. To keep up to date with developments surrounding the ACM roll-out, please visit the ACM webpage periodically, as well as the Customs Modernisation webpage – http://www.sars.gov.za/home.asp?pid=60547 Brief history, current status and next steps – • The development of the e-RFM has been completed and testing has commenced on 15 October 2011.
• The transmission of live data to the ACM system has commenced from 17 November 2011.
• The registration of road hauliers is an ongoing process that has been underway since August 2011.
• The Customs Modernisation Team and the SARS: Customs Trade Administration Division have, with the assistance of the Road Freight Association (RFA), held a series of stakeholder awareness workshops around the country – Johannesburg (19 October), Cape Town (4 November), Durban (18 November), Johannesburg (25 November) and Johannesburg (7 December).
• Bi-weekly cargo technical workshops are held in Johannesburg with traders, service providers and clearing agents.
• The CUSCAR DMG has been updated (v-20-20120309) to include Crew details. Testing of this CUSCAR is currently underway and the addition of the mandatory crew segment will be rolled out to the live ACM system shortly.
