Advisory on China Customs Advanced Manifest Requirements

Starting today June 1st, 2018, the General Administration of Customs of the People’s Republic of China (GACC) is changing its China Customs Advanced Manifest (CCAM) requirements for imports and exports according to GACC Announcement No. 56. The new requirements include data that must be electronically shared with the GACC for all inbound and outbound imports and exports from China. This includes sensitive identification numbers for corporations, sole-proprietors, and individuals importing and exporting in China — including Employee Identification Number (EIN) and Social Security Number (SSN).

Implementation Details

• China Customs Advanced Manifest (CCAM) enforcement wherein Advanced Manifest must be submitted to China Customs 24 hours prior to cargo loading on vessels sailing to/from China mainland ports
• The manifest data must be accurate and complete for all goods under the Bill of Lading (BL)
• Full details of the Shipper and Consignee (or Notify Party if Consignee is To Order) must be provided in the shipping instruction (SI)

Enterprise Codes Required

Enterprise code of shipper/consignee/notify party in China:

• Unified Social Credit Code (USCC) or Organization Code (OC) is required as Enterprise codes
• If the shipper or consignee in China has a Unified Social Credit Code (USCC), provide the USCC in the form of “USCI + USCC code”
• If there is no USCC, provide the organization code in the form of “OC + organization code”

Enterprise code of shipper/consignee/notify party other than China:

• Non-China shipper/consignee/notify party’s Enterprise code is required
• Examples: Japan – Legal Entity Identifier (LEI); USA – Employer Identification Number (EIN) or Central Index Key (CIK); UK – Company Number or VAT Number

Recommendation

It is likely if you are an individual or sole operator shipping goods to and from China to the U.S., that GACC will require your personal SSN to satisfy the new requirement. We strongly recommend signing up for an EIN instead – and where possible incorporate to an LLC to limit any potential exposure. The process to get an EIN is easy and low-cost with the IRS.

TL;DR

• Advance manifest requirements put an obligation on the carrier or forwarder to file data before loading.
• The data comes from the shipper, so accuracy upstream determines whether the filing succeeds.
• Inaccurate or late data creates delay risk at the origin, before the cargo moves.

What advance manifest compliance depends on

Element	What to confirm
Filing party	Who is responsible for submitting the manifest data
Deadline	The filing window relative to loading
Data set	Which shipment, party and cargo fields must be provided
Source accuracy	Who provides the commercial data and how it is verified
Exception handling	What happens if data is late or amended after filing

Upstream accuracy: manifest data is filed before loading, but it originates with the shipper. Errors or late information therefore create risk at the origin rather than at destination.

Frequently asked questions

What is an advance manifest requirement?

A requirement to submit specified shipment data electronically before the cargo is loaded, so the authorities can assess it in advance.

Who is responsible for filing advance manifest data?

Generally the carrier or their agent files, but the underlying commercial data comes from the shipper. Confirm the responsibility split in your booking terms.

What happens if manifest data is late or wrong?

It creates delay and potential penalties at the origin. Provide accurate data early and confirm how amendments are handled.