A clear distinction between goods and cargo security filing for reliable data

FIATA published today its Position Paper on the Dual Filing for ADVANCE SECURITY DECLARATIONS in accordance with the World Customs Organization (WCO) SAFE Framework of Standards.

FIATA acknowledges the authorities’ prerogative to decide on the value of data elements in terms of risk analysis, it is however the task of the stakeholders to provide the authorities with good recommendations on the best possible ways in which the information required is to be submitted, by the party that has that information, with the least possible disruption for the supply chain and in line with existing, long established international trading practices, many of which are reflected in a series of international conventions.

The current SAFE clearly distinguishes between transport and trade transaction related information. This is a logical choice, and there is concern within FIATA’s membership that some governments or governmental organisation may deflect from this approach to compress advance electronic data requirements into a Single Filing System by merging the goods and cargo declarations into one and making the carriers responsible for it.

Stephen Morris, Chairman of the Customs Affairs Institute of FIATA, made the following comment: “FIATA has consistently taken the view that the definition of the data-elements to be provided and the person or persons responsible for providing them cannot be artificially dissociated. It is not acceptable to encourage national authorities to create a legal requirement for a party to provide information that it does not have or run the risk of create turbulence in different parties’ legitimate and long established proprietary and confidential business arrangements. We work in a “supply chain”, where each party has clear rights and responsibilities, normally in respect of its immediate interlocutors. Artificially altering these arrangements may damage the interest of some of them, but more importantly it may really deteriorate the quality of data. What may appear at first sight as saving, experience tells us costs more money in the end. A wise investment in due time is the best economy governments can make.”

For the full text of the position papers (3 pages) please go to:


5 March 2012

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