TCC26-0090 Closed: CBSA EDI and eManifest Outage Grace Period Ends June 16

TCC26-0090 Closed: CBSA EDI and eManifest Outage Grace Period Ends June 16

CBSA closed bulletin TCC26-0090 on June 9, ending the Systems Outage Contingency Plan that ran from April 25 through early June. EDI and eManifest portal transmission is back to normal, and the grace period for Administrative Monetary Penalty System contraventions related to electronic data transmission ends June 16 at 23:59 ET. After that, the usual AMPS enforcement resumes.

If your broker filed under the contingency plan, this is the week to confirm cargo-control records reconcile, eManifest ACE/ACI linkages closed properly, and any paper workaround submissions during the outage have corresponding electronic records on file now. The grace period was never a blank cheque; it covered reasonable delays in electronic filing caused by the system being down. It did not waive the underlying regulatory requirement to transmit data correctly once the system came back.

What the Outage Contingency Plan Covered

For six weeks, CBSA accepted paper copies of cargo-control documents and eManifest submissions when the EDI channel or portal was unavailable. Customs brokers, carriers, and freight forwarders operating under the Pre-Arrival Review System (PARS) were told to file paper and backfill electronically once connectivity returned. Most border crossings and marine terminals had a desk process; the Port of Montreal sufferance warehouses saw the highest volume of manual submissions because container throughput didn’t slow down just because the EDI pipeline broke.

The practical consequence: brokers filed Release on Minimum Documentation (RMD) releases manually, then had to match them to cargo-control numbers after the fact. If your cargo arrived between late April and early June, your broker likely has a reconciliation queue. The June 16 deadline means CBSA expects that queue cleared by then.

AMPS Enforcement Resumes After the Grace Period

The AMPS Master Penalty Document sets fixed penalties for eManifest and cargo-control transmission failures. Common contraventions during an outage and recovery period include:

• Late eManifest submission (C071): CAD 250 to CAD 1,000 per occurrence, depending on how late and whether it’s a repeat offense.
• Incorrect cargo-control number on the CAD (C064): CAD 250 per filing.
• Failure to link eManifest to the cargo-control document (C074): CAD 500 to CAD 1,000.
• ACI/ACE transmission errors that prevent advance screening: CAD 1,000 and a removal of release-prior-to-payment privileges until corrected.

The grace period suspended issuance of these penalties for contraventions directly caused by the system being down. It did not suspend the requirement to file correctly once the system was back. If your broker transmitted on June 10 and the data was wrong, that’s not covered by the grace period. If your broker couldn’t transmit on May 15 because the portal was offline and filed manually, that is covered, but only if the electronic backfill happened promptly after June 9.

CBSA has historically been reasonable about system-caused failures. They are not reasonable about sloppy record reconciliation after the system comes back. If a carrier or broker waited until June 14 to start matching paper filings to cargo-control numbers, that’s a you problem, not a systems problem.

What Importers Should Check This Week

If you imported between April 25 and June 9, pull the brokerage file for each shipment and confirm:

• The eManifest or ACI transmission shows a confirmed cargo-control number and a timestamp before or shortly after arrival.
• The CAD or RMD release paperwork references that cargo-control number correctly.
• Any manual or paper submission during the outage has a corresponding electronic record filed after June 9.
• If you’re an NRI (Non-Resident Importer) using a service provider for eManifest and CAD filing, your service provider reconciled the queue and sent you a summary. If you haven’t received one, ask for it.

The majority of brokers cleared their backlog by mid-June. If yours didn’t, you’ll know soon because CBSA will issue a notice of penalty and your CARM Client Portal will flag the contravention. You can dispute it, but only if you have evidence the delay was system-caused and not procedural.

Longer Outages Expose Weak Spots in NRI and Multi-Party Filing Chains

The six-week duration of TCC26-0090 was longer than most. CBSA has had EDI hiccups before, but they’re usually measured in hours or a day. This one ran into the May long weekend and crossed a month boundary, which meant brokers had to reconcile April filings in early June while still clearing May cargo.

Non-Resident Importers felt it harder than Canadian-resident importers because NRI compliance is already a manual coordination exercise. The importer is offshore, the broker is in Canada, the carrier may be a third party, and eManifest filing responsibility sits with whoever controls the shipment at the time of arrival. When the EDI channel breaks, that coordination becomes email and phone calls instead of automated handoffs. If any party in that chain assumed someone else was handling the backfill, the importer gets the AMPS penalty.

We saw this pattern in late May: NRIs whose U.S. logistics providers arranged cross-border freight assumed the Canadian broker would handle all eManifest reconciliation. The broker assumed the carrier filed. The carrier assumed the broker did. CBSA doesn’t care who assumed what; the penalty goes to the importer of record on the CAD.

If you’re an NRI and you didn’t receive explicit confirmation from your Canadian broker that all cargo-control records from the outage period reconcile, send that email today. The grace period ends in three days.

One Last Check Before June 16

Most of this bulletin is procedural housekeeping. CBSA’s EDI and eManifest systems are stable again, and the grace period gave everyone reasonable time to catch up. If your filings are in order, June 16 comes and goes without incident.

If they’re not, the penalty notices start the week after. The contraventions that matter most: incorrect cargo-control numbers on CADs, missing eManifest transmissions for shipments that released under RMD during the outage, and unlinked ACI records for U.S.-origin freight. All three are fixable before the deadline if your broker knows they exist.

If you’re not sure your queue is clear, that’s a ten-minute conversation, not a next-quarter project. Get in touch. }

Source: CSCB