JP Customs – “NO” to Offense by NVO

(Source: Shipping Gazette of August 24, 2015 – free translation by BAL)

AFR (JP24): Filing Failure May Result “Do Not Unload”?
– Japan Customs Says “NO” to Offense by NVOs House BL –


The weekly shipping magazine “SHIPPING GAZETTE” from Tokyo has recently reported its observation on the Japan’s AFR (JP24) ruling situation by August 24, 2015 issue. Here is a free translated digest in English prepared by CS24 Editor.

Japan Customs Increased SPDs (Suspend) from July 2015

More than 18-months have passed since the new rules of JP24 took effect in March 2014. According to the Japan local market, there have been rather little cases where Japan Customs issued the advance notices of DNL/HLD/DNU and SPD. These are the Customs risk analysis indicators. The most serious offense indicator is SPD that may cause business disruptions in import cargo flow unless properly addressed by responsible parties. SPDs issued by Japan Customs are received by carrier only. Some carrier reports that more SPDs are being issued in recent days due to “No Filing” is made by NVO on its House BL. This is a serious offense to Japan Customs’s ruling which may have triggered Japan Customs’s aggressive enforcement against such Non-Filers if any.

Japan Customs May Take More Strict Action Over Non-Filer House BLs

 When JP24 was launched in March 2014, a variety of experts predicted that a full compliance of the rules particularly over NVO/forwarder may find some difficulties at the start. It is because of JP24 filings must be made before ship’s departure from loading port where local NVO/forwarders in overseas may rather find little information and lack of understanding to follow unless importers in Japan may fully address them to abide. In other words, during the past 18-months may effectively be conceived as a kind of grace period while Japan Customs never officially admits though. Today Japan Customs may feel now, after 18-months, to start making more strict governing on such unlawful cases that can be identified as; a. no filing at all, b. late filing, c. incorrect filing and more.

Corrective Actions by Carrier and Japan Customs’s Random Sampling with Repetitive Warnings

 It appears now that Japan Customs starts taking concrete actions against bad guys (who apparently ignore the JP24 rules) by having more random samplings together with relevant corrective measures using the 18-months old database records. It is an idea of “punishing a crime to make an example for others”. Although this approach does make sense, however, there still remains some difficulty to enforce the rules. Because NVO/forwarders at loading port in overseas have rather little contact and access with Japan Customs in Japan. In addition, SPD issued by Japan Customs can only be known by carrier first that places heavy burdens on carriers. They are obliged to have unnecessary business contacts and extra follow-ups through its own network for the benefit of NVO/forwarders. Carrier makes here a lot of efforts to expedite corrective action needed by House BL filers at loading and discharging port. Carrier has the top priority to avoid a situation where ships are detained by Japan Customs orders to process containers in question.

Burdened Carrier Plans Charging Fees On House BL To Recover Cost

 Carrier has potential risks to incur extra operating cost on handling/re-handling containers if NVO’s House BLs may receive SPDs which are subject to Japan Customs directive of “Do Not Unload”. Carrier also has another critical risk of delaying ships if any disruptions may have involved. Thus, some carrier is indicating that incurring extra cost if any can be charged to NVO/forwarders who failed to make required JP24 filing. Japan Customs is trying very hard to keep everyone well informed about its policy initiative to have the new rules be fully met by the responsible parties.

(By N. Hitani – Chief Editor, Shipping Gazette by The Japan Press)