CBP Issues Guidance on Manifest, Entry Requirements When Multiple Shippers/Consignees Involved

Carrier Responsible for Identifying Each Shipper and Consignee Pair

CBP states that in the past, shipments from a single shipper, with a single purchaser, to multiple consignees would be consolidated under a single entry and PAPS number.

With the advent of ACE e-Manifest, the truck carrier is now responsible under the Trade Act to identify each shipper and consignee pair as a separate item on the manifest. As per the regulations (19 CFR 123.92), carriers achieve this by using multiple Shipment Control Numbers (SCN), one for each shipper/consignee pair. CBP notes that ACE is designed to accommodate this process.

Brokers May Consolidate Multiple SCNs under a Single Entry Number

Brokers may consolidate multiple SCNs under a single entry number, as per the regulations (19 CFR 141, Subpart D).

According to CBP, brokers should consult the regulations to determine the number of entries that should be filed based on commercial parties, shipment methods, and importer/broker contracts.

CBP adds that as long as each shipment is manifested, releasable, and covered under an entry, CBP officers should make every effort to release the trip.

"Deliver to Party" is the Manifest Consignee

For manifest purposes, the manifest consignee is defined as the "deliver to party" from the contract of carriage that brings the goods to the U.S.

Goods intended to be delivered to multiple destinations in the U.S. at the time of importation need to have the consignee identified at the shipment level. Some examples include (not an all inclusive list):

• Single shipper with multiple deliveries arriving in the U.S. under the contract of carriage of the delivering carrier - each consignee would need to be identified by a separate shipment record with its own SCN.
• Single shipper with a single delivery to a distribution facility - additional distribution may take place but is not the responsibility of the arriving carrier. One consignee and shipper reported in a single shipment record identified with a single SCN may be reported.
• Multiple shippers, with a single delivery to distribution facility - additional distribution may take place but is not the responsibility of the arriving carrier. A separate shipment record with its own SCN is required for each shipper even though each shipment is consigned to the same consignee.
• Carrier delivering merchandise to UPS or the post office for distribution in the U.S. - each shipper/consignee pair requires a separate SCN. The exception to this is bulk mailings entered as printed material and sent into the mail stream. A single consignee is sufficient for this example.

U.S. Purchaser/Owner of Goods is "Ultimate Consignee"

The ultimate consignee for entry purposes is defined as the "U.S. purchaser or owner of the merchandise." If at the time of entry the purchaser or owner is not identified, then the "deliver to party" from the invoice will be used. CBP notes that the ultimate consignee is a commercial entity and entry rules apply.

(Note that ACE e-Manifest: Truck has already been deployed at all scheduled land border ports for advance cargo information purposes. e-Manifest: Ocean and Rail (M1) is expected to be deployed in the spring of 2009 and ACE e-Manifest for the air mode is expected sometime in the future.

See ITT's Online Archives or 02/07/08 news, 08020720, for BP note on the nationwide implementation of mandatory e-Manifest: Truck. See ITT's Online Archives or 01/27/09 news, 09012715, for BP summary of CBP deploying certain ESAR A2.1 capabilities on January 24, 2009, which help lay the groundwork for the M1 release.)

ACE Information Notice (dated 01/12/09) available at http://apps.cbp.gov/csms/docs/17436_786405067/Multiple_Consignee_version_6.pdf