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MEMORANDUM D20-1-1 REVIEW

MEMORANDUM D20-1-1 REVIEW. BCCC Export Sub-Committee April 10, 2013. Proposed Vision. Modernize Memorandum D20-1-1 to: Promote a more consistent and transparent application of the Reporting of Exported Goods Regulations and; Reduce errors associated with export reporting.

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MEMORANDUM D20-1-1 REVIEW

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  1. MEMORANDUM D20-1-1 REVIEW BCCC Export Sub-Committee April 10, 2013

  2. Proposed Vision • Modernize Memorandum D20-1-1 to: • Promote a more consistent and transparent application of the Reporting of Exported Goods Regulations and; • Reduce errors associated with export reporting.

  3. Progress To Date • Consultations have been held with over 30 CBSA, other government departments and external key stakeholders in 2012-2013 • The revision of the Memorandum has generated widespread interest. As such, comments from both internal and OGD stakeholders are still being carefully considered

  4. Changes based on your comments • “It would be a helpful point of reference to have a table of content at the beginning of the Memorandum.” • Publishing guidelines are that a Table of Contents should be included in D-memoranda over 10 pages. • When the draft is completed, a Table of Contents will be added if the document exceeds 10 pages. • Issues with hyperlinks and undefined acronyms • We agree that all websites should be hyperlinked and we will make sure that this is done when published. • We fixed the acronyms that were not properly defined in the body of the Memorandum. • “Although electronic transfers do not require an export declaration, they may be controlled and still require a permit.” • We agree and will make sure to indicate that permits may be required

  5. Discussion • The D20-1-1 draft does not offer the B13A form as a reporting option • Drivers for this change: • Promotion of electronic declaration methods (CAED and G7) • Facilitate the flow of low risk exports • Provide a transition period from now until changes to the Reporting of Exported Goods Regulations come into force mandating electronic reporting • Legal implications: • Until the regulatory changes, the B13A cannot be refused by the CBSA Are you supportive of this approach?

  6. Discussion • “The scenarios indicating the identity of the exporter lack detail and will lead to different interpretations.  There are many instances where the Canadian shipper of the goods may choose to be the exporter – and should have that right.” • Some stakeholders had suggested to retain the scenarios indicating the identity of the exporter • The CBSA is cognizant of the various INCOTERMS that may be utilized by trade chain partners • The Canadian company has no commercial responsibility for performing export customs – Incoterms 2010 EXW • The Canadian company does have commercial responsibility for performing export customs – Incoterms 2010 FCA, FOB, etc. • The CBSA suggests to remove the scenarios from the D20-1-1 to allow for various Incoterm possibilities Are you supportive of this approach?

  7. Next Steps We expect to publish Memorandum D20-1-1 in the coming months as soon as the final CBSA and OGD consultations are completed.

  8. Questions? Beatrix Gokey Senior Program Advisor Export Programs Beatrix.Gokey@cbsa-asfc.gc.ca Tel: 613-957-0645

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