BOC clarifies policy on wrong registry number in the export declaration

Encoding by the shipper of the wrong registry number in the goods declaration will not be considered a clerical error if the change in the registry number was made by the shipping line, according to a Bureau of Customs (BOC) official.

Jenny Diokno, chief of the Export Division of BOC at the Port of Manila, made this clarification at a recent webinar on the processing and cancellation of the Export Declaration-Single Administrative Document (ED-SAD).

Diokno said this exemption to the rule on clerical errors is based on Assessment and Operations Coordinating Group Memo No. 25-2021 released January 8 this year providing the “guidelines on the wrong encoding of registry numbers in the export declaration in the E2M System.”

The memorandum states that under Customs Administrative Order (CAO) 01-2020, encoding of the wrong vessel registry number in the goods declaration that was lodged in the Electronic-to-Mobile (E2M) system is considered as a clerical error.

However, “for changes initiated by the shipping lines and considered as beyond the control of the exporter, the same shall be subject to cancellation in the E2M system without penalty,” the memo says.

Only if the wrong registry number was encoded by the declarant will a penalty be applied for the clerical error made, Diokno emphasized.

Last January 11, the BOC implemented the Online Release System (OLRS) for the export declaration, which requires exporters to now input the registry number in the ED-SAD before lodging the declaration in the E2M system.

Customs Commissioner Rey Leonardo Guerrero issued on December 7, 2020 the memorandum implementing the OLRS. The memo states that from January 11, “lodgment of the Export SAD without the Registry Number will not be accepted by the E2M System.”

Diokno in her presentation reminded exporters that they may file their export declaration only once because making multiple lodgments for the same export in the E2M is not allowed.

She advised shippers that if there are changes or amendments to the shipping details (port of loading, registry number, vessel number, container number, etc.) after the ED-SAD has been lodged, the remedy is to just cancel the declaration to avoid penalty.

Diokno explained that under CAO 01-2020, any clerical errors made on the goods declaration merits a penalty of P5,000.

“I cannot overemphasize the importance of declaring the goods [correctly]-dapat kailangan correct ang mga details sa goods declaration because every error made there’s a corresponding P5,000 penalty.”

Last year, the Philippine Exporters Confederation, Inc. (PHILEXPORT) called for a review and suspension of CAO 01-2020, saying the policy is a “huge financial burden” on exporters because of the heavy penalty it imposes on clerical errors in the goods declaration for export.

Meanwhile, Diokno said that the procedure for SAD cancellation requests is as follows:
Write a request letter addressed to the chief of the Export Division at the port of loading
Accomplish the SAD cancellation form indicating the details to be changed
Upload the letter request and relevant documents on the customs portal using the original ticket used previously for the same ED for faster processing
Once the SAD cancellation request is approved and posted on the customs portal, re-lodge a new SAD reflecting the correct details

Processing of the request takes about 30 minutes.

On the payment of clerical errors, Diokno said the stakeholder needs to reopen the same ticket, as this is where BOC will provide the order of payment. The shipper will then pay the corresponding penalty at the nearest collection or cash division in the port of loading, and upload the receipt to inform BOC that the penalty has been paid.

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