Electronic Sealing of Containers

Gone are the days where a jurisdictional officer had to supervise the stuffing of export cargo. The Central Board of Excise and Customs (CBEC) has introduced a concept which enables the exporters to self-seal their containers using electronic seals. Such a measure will result in the reduction of transportation cost, as exporters may not have to incur MOT (Merchant Overtime) charges with respect to the supervision, combined with the fact that the time taken for moving the goods will be significantly lower. The initiative will be processed through RFID (Radio Frequency Identification) e-seal. This article is a brief account on the various pre-requisites pertaining to the recently launched system of electronic sealing of containers by the CBEC.

Applicability

Electronic sealing of containers can be adopted only for fully loaded container that is sealed at an approved premise, by an authorized exporter. Exporters who were availing ceiling at the factory premises under the previous system of supervision automatically qualify for electronic sealing of containers. Further, exporters who have been availing supervised sealing can automatically start electronic sealing of containers without any approval or permission from the jurisdictional commissioner.

Also, entities that are granted Authorized Economic Operator (AEO) status can electronically self seal containers regardless of whether they were involved in self-sealing or supervised sealing. Finally, all exporters having GST registration and filing GST returns can start electronic sealing of containers after obtaining approval from the respective jurisdictional Commissioner.

GST Registration and Return Filing

Only exporters who have GST registration and filing GST returns can bring export goods to a CPS/ICD for stuffing and sealing of container or electronically seal containers. Further, GST registration is now mandatory for importing goods in India. Hence, its best for those involved in import or export business to obtain GST registration at the outset.

Procedure for Electronic Sealing of Containers

Only full container loads can be electronically sealed by eligible exporters without the supervision of a Customs Officer. If a full container load is received at a port or ICD with electronic self-sealing RFID, then it would be deemed to be the equivalent of a container sealed under the supervision of an Officer.

Full containers brought to ports without RFID e-seals would be taken to a CFS or allowed direct port entry and subject to usual RMS treatment. Similarly, Full Containers Loads arriving at ICDs, without RFID e-seals, will be subject to usual risk management parameters. Finally, in case of good reasons or intelligence to warrant inspection or if the electronic seals are tampered, then the containers would be subject to the normal processing with supervision.

Intimation of Details

The jurisdictional customs officer has been relieved of supervision responsibilities, but the concerned officer must be duly informed by the exporter about the details of premises where container stuffing is undertaken. An exporter who intends to pursue electronic sealing should inform the jurisdictional Customs Officer at the rank of Superintendent or Appraiser of Customs at-least 15 days before the first planned involvement of the consignment. The Jurisdictional Superintendent or Inspector of Customs will conduct an inspection on the premises to validate its viability and then submit a report of the same to the Deputy/Assistant Commissioner of Customs, who in-turn will forward the proposal to the Principal Commissioner/Commissioner of Customs. The Principal Commissioner/ Commissioner of Customs is vested with the rights of granting permission for electronic sealing.

Once the permission is granted, the exporter is required to furnish an intimation to the jurisdictional Superintendent of Customs prior to each session of electronic sealing.  On the other hand, if the report of the inspection conducted by the concerned authority is not satisfactory, the exporter needs to bring the goods to the CFS/ICD/port for sealing.

Clearance of Export Goods

Exporters who are intent on clearing export goods without the assistance of a customs broker i.e. on self-clearance, need to file the Shipping Bill under digital signature.

Sealing Specifications

The exporter should seal the container with tamper-proof electronic seal of the specified standard. A unique number should be assigned to the Electronic Seal, which should be mentioned in the shipping bill. In addition to it, the exporter should specify details such as his/her name, IEC code, GSTIN number, description of the goods, tax invoice number, name of the authorized signatory and shipping bill number in the electronic seal.

Government Circular on Electronic Sealing of Containers

The government notification on electronic sealing of containers is reproduced below for reference:

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