Professional Documents
Culture Documents
RELEASE
STUDY
Glossary
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Message from Chief Commissioner, Mumbai Zone-1
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1. EXECUTIVE SUMMARY
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1.1 Introduction and Context
1.2 Purpose and Objective
1.3 Guidelines of WCO & CBIC
4. EXPORT TRS
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4.1 Analysis of Export Release Time
4.2 Export TRS Timeline & Approach
4.3 Release Time for Facilitated & Non-Facilitated SBs
4.4 Release Time for Inspected & Examined SBs
4.5 Analysis of LEO to EGM Process
4.6 Release Time for Top Export Commodities
4.7 Release Time for Top Exporters
5. FINDINGS OF RESULTS
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5.1 Findings & Opportunities
5.2 Top Import Commodities Release Time Performance
5.3 Top Importers Release Time Performance
5.4 Group wise Release Time Performance
5.5 Group wise Importer Query Analysis
5.6 PGA wise Release Time Analysis
5.7 Release Time Analysis for Different Types of FacilitatedBs/E
5.8 Release Time Analysis for Bulk & Non Bulk Cargo
5.9 Release Time Analysis for WarehouseBs/E
5.10Release Time Analysis for X-Bond Bs/E
5.11Release Time Distribution Between Trade & Customs
I am happy to find that the team under the leadership of Smt. Prachi
Saroop, Commissioner of Customs has worked hard to conduct the Time
Release Study (TRS) 2019 in respect of Mumbai Customs Zone – I pertaining
to Mumbai Port and ICD (Mulund). The WCO TRS is mentioned in Article 7.6
of the WTO Trade Facilitation Agreement (TFA) as a tool for Members to
measure and publish the average release time of goods. WCO endorsed Time
Release Study is an effective tool to understand the time lines involved in
clearance of import and export cargo which helps in identifying areas for
improvement in the Customs clearance process so that steps can be taken to
further enhance trade facilitation. TRS 2019 is an excellent analysis regarding
release of goods in respect of Mumbai Customs Zone – I and has a
comparative study regarding the release times in respect of TRS 2017 and
TRS 2018.
I congratulate Smt. Prachi Saroop and her entire team for preparing
TRS 2019 which I am sure will provide an insight not only to Customs officers
but also our stakeholders which will help Customs in achieving much higher
service delivery standards.
(B. Bhattacharya)
Chief Commissioner of Customs,
Mumbai Zone – I
Dated: 19th July, 2019
Time Release Study (TRS) is one of the important Initiatives taken by Indian
Customs for facilitation of Trade and reduce time and cost of import clearance
improved India’s Trading Across Boarders rank to 80. The Study has been
undertaken in accordance to guidelines issued by WCO and CBIC considering
new initiatives taken by Govt. of India for further improvement of trade
facilitation and release time of import and export cargo.
During 2018, CBIC has initiated one more measure for further facilitation of
trade and reduce Release Time of Import Cargo –Self Registration Facility on
ICEGATE website which enables Importer/CB to register the goods himself
without needing to physically apply before the Custom Officer.
As per the WCO - One of the methods used for the review of clearance
procedures is to measure the average time taken between the arrival of the
goods and their release. This facilitates Customs to identify both the problem
areas and potential corrective actions to increase their efficiency. The use of
automation and other sophisticated selectivity methods can allow Customs to
improve compliance and at the same time improve facilitation for the majority of
low risk goods.
Measuring the time taken for the release of goods also meets the concerns of
trade circles regarding long delays in Customs clearance. It helps Customs to
respond to trade requirements where the operators need to plan ahead for the
movement of goods across borders in order to meet tight production schedules
and just-in-time inventory systems that require forward planning.
The time required to release goods has also increasingly become the measure
by which the international trading community assesses the effectiveness of a
Customs administration. The Time Release Study provides guidance to Customs
administrations on the best way to apply this method of internal review.
The said study is to cover the time taken at various stages in customs
clearance processes in accordance with WCO (World Customs Organization)
guidelines.Refer to article-7 of WTO Trade Facilitation Agreement as under:
6.1 Members are encouraged to measure and publish their average release time
of goods periodically and in a consistent manner, using tools such as, inter alia,
the WCO Time Release Study.
6.2 Members are encouraged to share with the Committee their experiences in
measuring average release times, including methodologies used, bottlenecks
identified, and any resulting effects on efficiency.
The CBIC (Central Board of Indirect Tax & Customs) vide its letter vide F. No.
450/3/2012-Dir (Cus.) dated 02.01.2015 issued guidelines and instructions
for preparation of Time Release Study at each Custom Location across the
country. This Study is undertaken in line with strict compliance of guidelines
of WCO and CBIC.
The Import TRS sample is categorized into the Import sea cargo volume at
NCH and at ICD Mulund, and is further broken down into RMS facilitated and
Group Assessed Bills of Entry (Bs/E). The RMS Facilitation has been divided
into three categories
1. No Assessment-No Examination
2. No Assessment-Only Examination
3. Only Assessment-No Examination
The Group assessed B/Es are also divided into First Check Bs/E and Second
Check Bs/E.
According to the WCO guidelines, the sample period chosen should be one of
‘normal’ traffic, avoiding seasonal variations. Based on data of ICES, January
was chosen as the ‘middle-of-the range’ activity. The Time Release Study
should ideally include all the declarations processed in a period of at least
seven consecutive working days, however, the sample period for analyzing the
time release was chosen from01.01.2019 to 15.01.2019. This is generally
considered as a normal period for various activities at Mumbai Custom Zone-
1 and the longer period gives a fair picture of the release times for the various
activities.
The arithmetic mean between the arrival of the goods and their
release into the economy via a standardized system.
TRS is the special tool developed by the WCO to measure the relevant
aspects of the effectiveness of operational procedures carried out by Customs,
PGAs and private sector stakeholders in the standard processing of imports
and exports.
Plan
Make
Recommendation
TRS CYCLE Test Validate
Identify Calculate
Findings Results
Analysis
The stages in the release of Imported Cargo at a seaport can be classified into
following stages:
The WCO Time Release Study (TRS) measures relevant aspects of the
effectiveness of operational procedures carried out by Customs and
other regulatory actors in the standard processing of imports,
exports and in transit movements.
The Bs/E filed during the sampling period (compared to two previous years)
were categorized into various types as below:
(a) facilitated bills of entry with assessment only and with both
assessment and examination
(b) non facilitated bills of Entry
(c) first check bills of entry
(d) Second check bills of entry
(e) Advance bills of entry
(f) Normal bills of entry
(g) AEO bills of entry
(h) X-bond bills of entry
Group Wise: The time taken in release of goods, by the various Import groups
in the Zone has also been looked into.
The Shipping Bills filed during the sampling period were categorized into
types as below:
Shipping Bill-The average export release time is calculated for following
categories of 349 S/Bs filed during the sample period:
(a) Facilitated S/Bs
(b) Non Facilitated (Assessed) S/Bs
(c) S/Bs selected for Inspection only
(d) S/Bs selected for Examination
Commodity Wise: The Study covers average release time in respect of top
export commodities exported from NCH.
Exporter Wise: The average release time in respect of top exporters at NCH,
is also analysed with graphical presentation.
1. Live data for Bs/E filed during the period 01-15 January at NCH
(INBOM1), 2019 is called from Saksham Seva, ICEGATE, (DG
Systems) New Delhi.
2. End date of the TRS is taken as those when more than 95% of the
Bs/E have been given OOC. Thus, out of total filed 1076 Bs/E, 1044
(97%)Bs/E were cleared successfully as on 23.01.2019, therefore,
23.01.2019 is taken as end date of clearing process of the current
TRS.
Processing the Normal B/E: The importer is to file a bill of entry before the
end of the next day following the day (excluding holidays) on which the
vessel carrying the goods arrive at customs station at which such goods are
to be cleared for home consumption or ware- house. The law also provides
for imposition of charge for late filing of bill of entry without sufficient cause
for such delay. These Bs/E are filed within 48 Hrs, after the grant of entry
inwards by the Boarding officer.
Processing the Advance B/E: Filing of the advance B/Es enables the
handling of the documents submitted to the Customs, before the arrival of
the goods within thirty days of the expected arrival of the vessel. These are
filed prior to grant of entry inwards. In case the B/E is fully facilitated, the
importer can continue and make payment of customs duty even before the
entry inward and be ready for registration of the goods immediately on
arrival of the cargo. Even so, the time in such cases is calculated from the
time of grant of entry inward.
CBIC has introduced SWIFT which is a single window for clearance of the
cargo, that empowers all PGAs to ICES access to the submission of
declaration made by Importer/CB in respect to B/E filed.
Importer / CB
Filing of
Facilitated Assessmentb
Bill of Entry
BE yGroup
Duty Payment
Examination
OUT OF
CHARGE
Duty Payment
Registration &
Examination
Registration
OUT OF
CHARGE
Filing of
Importer / CB B/E
Final
Assessment
by Group
Duty Payment
OUT OF
CHARGE
As per the National Trade Facilitation Action Plan (2017-2020) the release of
Sea port cargo is 48 hours, while, interestingly, the law provides for the
importer or his authorized representative to file bill of entry for nearly up to
48 hours after the grant of entry inward. With the aim, to study and analyse
the average release time of goods in Customs Zone-I, data for all the Bs/E
filed during the given period was called from the central ICES (Indian
Custom EDI System), New Delhi. Total number of Bills of Entry provided by
ICES team selected for the sample period i.e. 01.01.2019 to 15.01.2019
are1044, which included the 372 prior/advance Bs/E. It is also worthwhile
to mention that the sample period included a weekend. This was done to
study the time release of imported cargo in an uninfluenced manner.
Now, detail analysis of results obtained for each category are being shown
below along with graphical representation in compare to results from
previous TRS:
Bs/E facilitated at both levels i.e. Assessment & Examination, are being
considered here for analysis. Total average Cargo release time for Facilitated
Bs/E has improved significantly in current TRS. It is reduced by 39% and
30% as compared to year 2017 and 2018 respectively. Moreover, total
average time in registration to OOC is also reduced substantially by 64%
and 57% since 2017 and 2018 respectively. This includes both the Advance
and Normal Bs/E. The time taken by Customs in giving the OOC after
registration is minimum, however there is definitely the scope to reduce the
same in payment of duties and registration of the cargo by the
importers/CBs. The time attributable to the Customs in this case has
reduced from 3.19 hours (24%) to 1.27 hours (16%) since 2017, while that
taken by the importers is 129.1 hours (97.6%) to 79.7 hours (98.4%).
There has been good improvement in the timelines on all fronts, for this set
of Bs/E, which happens to be the largest share in the Bs/E (91%). The dwell
time has reduced by 60% and 30% as compared to years 2017 and 2018
respectively. The time taken by Customs is 27.39 hours (28%) while the
importer’s share in the total time is 70.26 hours (72%). Moreover, total
average time in registration to OOC also reduced substantially by 68% and
42% since 2017 and 2018 respectively and presently stands at less than 5
hours. However, with more outreach programs to popularize the online
schemes available such as e-SANCHIT for document uploading, for online
and faster registration of goods etc. and identification of problem areas in
the subsets of this set of Bs/E, further improvement is possible.
Reduction in dwell time is noticed for this category of the Bs/E to the extent
of 252 Hrs in year 2017 to 156 Hrs in 2018 to 105 Hrs in 2019. The time
taken by Customs is 25.84 hours (24.7%) while by the importers is 78.78
hours (75.3%). As is apparent, most time is taken in filing the B/E i.e. in the
first stage. This area needs to be focused upon and after identifying the
reasons outreach programs will help in sensitizing the trade with the need to
file the Bs/E faster and reduce the transaction time. The department could
also reduce the time given to file the B/E after the grant of entry inwards.
The educational outreach programs help in reducing the time taken by the
importers to reduce time taken in their areas. The normal Bs/E chart above
includes the 1st and the 2nd check Bs/E both.
Total Average Cargo release time for First Check Bs/E has improved
significantly in current TRS. It is reduced by 69% and 18% as compared to
year 2017 and 2018 respectively. Moreover, total average time in submission
to assessment is also reduced substantially by 60% and 29% since 2017
and 2018 respectively. This excess time taken is on account of the atypical
nature of assessment required for some commodities were self-assessment
is difficult for the importers.
The significance of being an AEO is palpable from the chart above, which
shows goods clearance time to be much lower than the average release time
of cargo at NCH, Zone-I.
Total Average Cargo release time for the Facilitated Bs/E of AEO Clients has
improved significantly in current TRS. It is reduced by 31% and 21% as
compared to years 2017 and 2018 respectively. Moreover, total average time
in registration to OOC is also reduced substantially by 45% and 65% since
2017 and 2018 respectively. It is now at just over an hour. For the Bs/E
filed under this category, the assessment is completed in very limited time
given the fact that it is filed by an AEO Client of the Customs.This TRS
report comes to the conclusion that the AEO client programme needs to be
continued to be pursued and interact closely with them to encourage them
to file advance Bs/E. Identification of constraints that inhibit their being
able to clear the stages 3 & 4 in the chart above will help in streamlining the
processes further.
49.96
Total Average Cargo release time for Facilitated Advance Bs/E of AEO
Clients has improved significantly in current TRS. It is reduced by 36% and
39% as compared to year 2017 and 2018 respectively. Moreover, total
average time in registration to OOC is also reduced substantially by 43%
and 71% since 2017 and 2018 respectively. It is now at just over an hour.
For the Bs/E filed under this category, the assessment is completed in very
limited time given the fact that it is filed by an AEO client of the Customs.
TRS for Export is being taken up formally to gauge the export release time
by adopting procedure based on data obtained through DG Systems, New
Delhi. Total number of Shipping Bills filed for the sample period i.e.
01.01.2019 to 15.01.2019 are 349, out of which 311 were facilitated SBs.
All 349 Shipping bills were considered for this study.
There are two levels of Facilitation for Shipping Bills- at Assessment and at
Examination. Every S/B passes through RMS after submission in ICEGATE.
On the basis of prefixed criteria, RMS decides that the S/B will move
directly to Examination queue or to Assessment by Customs.
As per the National Trade Facilitation Action Plan (2017-2020) the release of
Sea-port Export cargo is 24 hours. The Export process begins with the
filing/submission of S/B in ICES through ICEGATE. As per EDI System,
Shipping Bill (S/B) has to be registered within 15 days from date of filing
otherwise it gets removed automatically.
After filing of S/B, goods are allowed to enter into Customs Area i.e.
Port/CFS for registration of Goods in ICES by Custom Officer followed by
inspection/examination as applicable. Thereafter, Custom releases the
goods for export by issuing Let Export Order (LEO) in ICES. Thus, Customs
is involved only at Registration to LEO stage.
The Study provides impressive results to confirm that NCH maintains a high
level of performance in trade facilitation and predictable delivery of release
time. The Summary of average release time for different types of Bs/E is
shown as under –
On the other hand, First Check Bs/E take longer release time compared to
other type of Bs/E. However, First Check Bs/E at NCH constitute only 2.7%
of the total. In fact, First Check Clearance is completely different process of
clearance, already explained, which takes longer time due to a number of
reasons, few of them are as under –
The above table confirms that CTH-29025000- Styrene has the least average
release time at 14.01 Hrs, whereas CTH-29152100-Acetic Acid has average
release time of 53.89 hours. The average release time for these top 20
commodities is 72.02 Hrs.
Bharat Petroleum, Hindustan Petroleum and Indian Oil import mainly Base
Oil&Crude Oil in bulk form. After assessment, Bs/E of these goods is sent to
Division Office for examination. For bulk cargo, total out turn (OT) quantity
is ascertained after discharge of total quantity from Vessel to Tank followed
by deep measurement of the same by designated Surveyor in presence of
Embarkation HQ filed 04 Bs/E during the TRS period, but 3 Bs/E out of 4
get stuck due to a system error related to IGM which took more than 300
Hrs in rectification of the same.
Analysis of the nature of queries shows that the groups 4, 5, 5B and 6 raise
most queries. The reasons for this are nature and sensitiveness of the goods
imported under said groups. The outreach programmes with the
stakeholders and changes by DG, System will help in fewer queries being
raised and faster clearance of Cargo.
Not many Bs/E in NCH, require the clearance from the PGAs. However, administrative
changes can reduce the time taken by the PGAs to reduce the release time for the
cargo.
The sample data contains nil BE for the category “No Assessment & Only
Examination”. Thus, details of Bs/E pertains to remaining both categories is
being shown below-
Referring Section 3.2 of the Study, only 94 (9%) Bs/E with No Assessment &
No Examination have been considered as Facilitated Bs/E. However, Overall
facilitated Bs/E are 394 which contribute around 38% of the total Bs/E.
While the fastest release time is of 55.94 hours for facilitated WH Bs/E, it is
much more than the expected time, given that there is hardly any time
taken by Customs of 0.48 Hrs, whereas trade took 55.46 Hrs in case of
Facilitated Bs/E.
On the other hand, highest release time is of 75.56 Hrs for Non-facilitated
Bs/E where Customs & Trade contribute 19.03 Hrs and 56.53 Hrs
respectively.
For total Warehoused (WH) Bs/E, Customs takes 15.48 Hrs while trade
takes 56.33 Hrs. Hence, percentage contribution of time taken by Customs
and trade for WH Bs/E are 21.6% and 78.4% of the total release time.
TRADE CUSTOMS
FACILITATED 79.67 (98.4%) 1.27 (1.6%)
NON FACILITATED 70.26 (71.9%) 27.39 (28.1%)
ADVANCE/PRIOR 56.24 (85.7%) 23.58 (14.3%)
NORMAL 78.77 (75.3%) 25.85 (24.7%)
FIRST CHECK 129.25 (65.3%) 68.54 (34.7%)
SECOND CHECK 72.90 (77.8%) 20.76 (22.2%)
TOTAL AEO Bs/E 67.28 (75.1%) 22.30 (24.9%)
FACILITATED AEO 75.76 (98.4%) 1.29(1.6%)
FACILITATED ADVANCE AEO 48.64 (97.4%) 1.32 (2.6%)
TOTAL Bs/E 71.11 (74%) 25.04 (26%)
During analyzing the TRS import data, Bs/E taking total release time more
than 300 Hrs are listed out as “Outliers”. Total number of such Bs/E are 23.
In order to find out the exact reason and stage of long delay, these Bs/E are
taken up for stage-wise release time study. Total release time has been
divided into time taken in all 05 stages of release process of import goods.
The Stage taking higher time comparing to other stages for each BE, has
been highlighted with red color for detailed examination of the cause of
delay. One stage is being selected for each BE for analyzing further.
The above list reflects particular stage of outlier contributing larger amount
for taking so high time in clearance of each BE. Analyzing the highlighted
stage will open the door to find out the actual cause of delay in total release
time. It is also observed that the stage “Submission to Assessment” is having
largest number of counts in highlighted category.
Registration to OOC 1 5%
The above results shows that stage- “Submission to assessment” has largest
number of outliers which counts more than 50% of the total outliers while
stage- “Registration to OOC” has only 1 (5%) outlier.
Out of total 23 outliers, following 04 Bs/E are being selected for detailed
study-
This B/E was filed for clearance of a vessel imported for breakage.
Mumbai Port (MbPT) is one of the few Ports, where such imports take
place. Clearance of Vessel imported for breakage normally take longer
release time as it requires to pass through a number of procedures
governed by Standing Order-10/2010 dated 18.05.2010.
While this is an atypical case, few such imports take place every
month at NCH.
Further, Importer took 142 Hrs to pay the duty after assessment by
Group officers. It is also noticed that importer/CB took 97 Hrs to
produce the B/E before Docks Officer for registration. On the other
hand, Custom took only 04 hours to complete the procedure of
registration, examination and grant OOC.
The importer took 404 Hrs to pay the duty. The duty was paid on
24.01.2019 (12:11PM) while BE was ready for payment on 07.01.2019
(04:29PM).
The B/E movement shows that it took 342 Hrs in registration from
date of payment of duty. The BE was assessed on 14.01.2019
(12:49PM) on the same day of submission of BE. Further, duty was
paid next day to the date of assessment. Also, it was granted OOC on
the same day of registration of BE in ICES.
In case of Bulk cargo like LPG, Base Oil, Crude Oil etc., Out Turn (OT)
quantity is ascertained after discharged from vessel into tank which
takes time to settle in tank. After release of all quantity in tank, deep
measurement is undertaken by surveyor in presence of Custom
Officer. Thus, OT quantity is ascertained and concerned Custom
officer posted at Division forwards quantity confirmation report to
Docks for registration in ICES.
LESSON FOR PGAs: Volume of Bs/E pertains to PGAs are very low,
however time taken by Animal Quarantine (AQ) of 7 days for a BE
needs to be improved.
(i) e-HELPLINE
(iii) e-SANCHIT
The officer concerned will now have access to a fully automated queue
of Bill of Entry (B/E) ready for granting clearance in ICES 1.5.
Turant Customs will reduce dwell-time of the goods that are pending
only for the grant of such clearance.
ICD Mulund was established in November 1991 spread 36.88 acres (147520
Sq. Meters). Indian Railways Central Line bisecting it into Mulund (East)
and Mulund (west) accommodates Import and Export Custom Clearance.In
the beginning, the CFS operated from Mulund (W) and handled only
Exports. In fact, it functioned only as an extension of Export
Commissionerate of the Bombay Customs House.
In November 1995, Mulund was notified as Customs area for the purpose of
import examinations as well. Later Mumbai Custom Zone-1 split into
Import, Export and General Commissionerate. The CFS Mulund was
assigned to the Commissioner of Customs (General), Mumbai, vide Standing
Order 7578/2000 dated 07.12.2000. Export and Import department merged
into a full fledge integrated and independent CFS from filing of import and
export documents, assessments, duty payments are undertaken at Mulund
itself.
In this section, the average release time, in hours, for different categories of
Bs/E filed for the import Cargo in ICD Mulund is being analysed. The
analysis in detail is as below based on the methodology elaborated (based on
WCO guidelines) in Sections 2.2 and 2.3:
The time taken by Customs is 52.3 hours (20%) while the importer’s share
in the total time is 206.3 hours (80%).
1 9 208.08 315.78
2F 1 0.05 205.07
2G 4 188.12 317.56
2J 83 17.34 242.20
3 63 15.61 241.41
4 19 92.54 385.23
5 2 253.49 328.96
5A 5 4.76 99.66
TRS for Export is being taken up formally to gauge the export release time
by adopting procedure based on data obtained through DG Systems, New
Delhi. Total number of Shipping Bills filed for the sample period i.e.
01.01.2019 to 15.01.2019 are 184, out of which 161 were facilitated SBs.
All 184 Shipping bills were considered for this study.
Mumbai Port has long been the principal gateway to India and has played a
pivotal role in the development of the national economy, trade & commerce.
The port has achieved this position through continuous endeavor to serve
the changing needs of maritime trade. Though traditionally designed to
handle general cargo, over the years, the port has adapted to changing
shipping trends and cargo packaging from break bulk to
unitisation/palletisation and containerisation. Besides, it has also developed
specialised berths for handling POL (Petroleum Oil & Lubricants) and
chemicals.
9.1 CONCLUSION
The NCH TRS provides a third set of measures relating to the clearance of
import cargo. This TRS allows comparative analysis between the previous
two studies. Analysis of difference in the measures identify changes in the
performance of Customs in clearing cargo at NCH, Mumbai. The findings
and opportunities identified are similar to the previous studies and NCH
should continue to work on these.
9.2 DISCLAIMER
While every effort has been made to ensure the compilation and
calculation of information in this publication is accurate, the TRS Project
Team does not accept any responsibility or liability for error of fact,
While the TRS Project Team has exercised all reasonable skill and care in
the preparation of data information and analysis in this report, it does not
accept any liability in contract, tort or otherwise for any loss, damage,
injury, or expense, whether direct, indirect or consequential, arising out of
the provision of information in this report.
9.3 ACKNOWLEDGEMENT
1. Mr P.V. Sudhir,
Senior Technical Director, NIC
New Custom House, Mumbai-I
THANKS