Electronic sealing – Deposit in and removal of goods from Customs bonded Warehouses

Electronic sealing – Deposit in and removal of goods from Customs bonded Warehouses. The Warehouse Regulations prescribe the affixation of a onetime-lock for transport of goods to be deposited in a warehouse or removed therefrom. Further Circulars 36/2017, 37/2017 and 41/2017 – Customs prescribe the use of “RFID tamper proof one-time-bolt seal” and providing of readers / procedure for its use by Customs.

Now, the Central Government vide Circular No. 19/2018 – Customs dated 14th June, 2018 has clarified that RFID sealing shall be extended to transport of goods for deposit in a warehouse as well as removal therefrom. Therefore, where ever the Warehousing Regulations prescribe affixing of a One Time Lock”, the importer or owner of the goods shall use RFID anti-tamper one-time-locks.

Considering the fact that goods may be removed through a variety of vehicles, different types of RFID OTLs, such as bolt seals) or wire – cable seal shall be used. The specifications, data elements and procedure to be used under the Regulations for Warehousing shall be as follows:

Types of Seals

(i) For containers (RFID One-Time-Bolt Seal)

(ii) For closed body vehicles (RFID Wire Cable seal)

  • (a) Each seal shall be a one-time-lock bearing a unique serial number and brand of the vendor.
  • (b) The RFID seal shall conform to ISO 17712: 2013 and ISO/ IEC 18000-6 Class 1 Gen 2.
  • (c) The manufacturer or vendor, as the case may be, shall be in possession of certifications required for conformance of the ISO standard.
  • (d) Before commencement of sales, the vendor shall submit self-certified copies of the above certifications to the Risk Management Division (RMD).

Procedure

  • (a) All licensees of customs bonded warehouses shall have to procure Readers for scanning of RFID OTLs at the bonded warehouse at their own cost.
  • (b) The licensee shall also procure RFID OTLs from the vendors for providing the same to importer, owner and exporter or in case of private bonded warehouses for their own use. It is clarified that licensees are free to procure RFID OTLs from any one or more vendors.
  • (c) The vendors shall be required to provide Readers to Customs locations. Readers already deployed by vendors to Ports and ICDs for RFID sealing can also be used for this procedure. Air Cargo Complexes, CFS and LCSs are also covered under this procedure for transport of bonded goods.
  • (d) Any importer permitted to remove goods for deposit in a warehouse shall obtain an RFID seal from the Warehouse where the goods are to be deposited.
  • (e) Vendors shall ensure that the TID number is captured in their data base and warehouse code of the licensee is linked to the same at the time of sale of seals.
  • (f) Vendors shall ensure that data can be uploaded from internet enabled Readers as well as desktops.
  • (g) Circular No 19/2016-Cus dated 20th May 2016 prescribes that the importer shall declare the warehouse code in the Bill of Entry for warehousing. The Out of Charge officer releasing the cargo for deposit in a warehouse is advised to match the warehouse code declared in the bill of entry with that linked to the seal. This procedure shall dispense the need for securing any space availability certificates by importers.
  • (h) The exporter of warehoused goods will be obligated to declare the physical serial number of the RFID OTL at the time of filing the online integrated shipping bill or in the case of manual shipping bill, before the container or cargo is dispatched from the warehouse.
  • (i) In case the RFID OTL is found to be tampered at the Customs Station at the time of export, then mandatory examination would be carried out by the Customs authorities.
  • (j) In case at the time of arrival of the goods at the warehouse, the RFID OTL is found to be tampered, then the licensee shall not permit unloading of the goods and shall inform the bond officer
  • (k) The “trip report” generated by scanning the RFID OIL at the destination customs station or warehouse, shall be printed and retained for records by the customs station, bond officer and licensee. This will enable discharge of the requirement of acknowledgement enjoined under the regulation (5) of the Warehoused Goods (Removal) Regulations 2016. However, this is notwithstanding the obligation cast on the licencee under Warehouse (Custody & Handling) Regulations 2016 for accountal of goods.
  • (l) For the purposes of risk management, if there is any inordinate delay in the due arrival of goods, the bond officer may be alerted by the customs station or vice versa.
  • (m) Where any procedure requires that goods removed from a warehouse shall move under physical escort by customs (e.g. as prescribed by circular 32/2016 regarding Duty Free Shops), the use of RFID OIL shall not apply.

The Principal Commissioner of Customs/Commissioner of Customs is duly empowered to permit movement of goods without affixation of RFID OTLs, where the nature of goods or their manner of transport so warrant (e.g. Liquid Bulk Cargo transported through Pipe Lines and Over Dimensional Cargo).

It is to be noted that the above procedure shall come into force with effect from 1st August 2018. [Circular No. 19/2018 –Customs dated 14th June 2018]