T he country is passing through a transition towards accepting the graduation which is very much prestigious at the same time challenging also. As an LDC, since last more than five decades we were used to enjoying a number of flexibilities as a WTO member, now the flexibilities will face erosion and we will be in a competitive free market regime where for sustenance, the country needs enough preparation.
Bangladesh government has already taken a Smooth Transition Strategy (STS) and a core committee and number of sub-committees have been formed to take preparation and strategies to meet graduation challenges. Business process simplification should be the core issue so that cost of doing business is reduced.
Trade Facilitation (TF) has been a priority to abate consignment releasing time which will ultimately reduce cost and bring competitiveness. Trade Facilitation Agreement (TFA) of the World Trade Organization (WTO) has acquired greater focus and urgency since it has been ratified the in April 2016. TFA recognizes the importance of regular performance measurement, and article 7.6 recommends measurement of average cargo release time, through Time Release Study (TRS) of World Customs Organization's (WCO). In recent years, the tool has been capturing a lot of attention worldwide in case of trade and investment issues.
Bangladesh has conducted four separate TRS for different ports (Benapol and Burimari land port, Chittagong Seaport) in 2019. Due to Covid-19 pandemic, the TRS could not be completed before 2022. Recently NBR has a conducted a consolidated TRS on three ports (Dhaka, Chittagong and Benapole) and released its findings in September 2022. TRS has been conducted with the assistance of WCO, Swiss State Secretariat for Economic Affairs (SECO) and Global Trade Facilitation Program (GTFP).
Currently customs release and clearance times are impacted by repetitive processes that allow other stakeholders to unduly influence the total time taken to release goods. As per the TRS of Chittagong Sea port (2014), the time taken in Chittagong for release of cargo for import was 11 days, 9 hours and 45 minutes and for export it was 4 days, 22 hours and 38 minutes. If we look into the average release time for import consignment in Singapore and India, it is 7 hour 27 minutes and 3days 23 hours respectively in 2019.
India has been able to increase their AEO operation very speedily which is around 5000, this could be one of the reasons for reduction of consignment releasing time.
The average time required to complete the import clearance process starting from arrival of the truck at the Benapole port to the final release of the goods is 10 days 8 hours 11 minutes (maximum time 35 days 8 hours 26 minutes, minimum time 1 hour 39 minutes) in 2022. While it was 6 days 23 hours in 2014 which shows a huge increase in cargo handling time at Benapole port which is about four days. The decline may be because of poor infrastructure in the land port areas and lack of capabilities in the port handling procedures and shortage of warehousing and storage facilities.
Steps for import at Benapole Land port was 42 for normal processing with an additional 10 steps needed to correct any errors was required in 2014, it has been reduced to 28 steps now which is a good example. However, in contrast, required days for customs clearance procedures have been increased significantly.
Steps for import at Chittagong port requires 32 steps as per TRS 2022 where as it was 25 as per TRS 2014. It is seen that even though steps have been reduced in both Benapole Land port and Chittagong port, time for releasing consignments have not been improved. Methodological issues can be examined further to see the reason behind the opposite picture. In case of Singapore there are three simplified steps for releasing consignments are pre-clearance dwell time, customs clearance dwell time and post-clearance dwell time.
TRS has given us some clear picture to consignment releasing time, process in different mode of customs clearing ports, in order to improve customs clearance process there is a need for integration of concerned stakeholders with the ASYCUDA World and the National Single Window (NSW). Progress or status of every steps of consignment release would need to be informed by the system (ASYCUDA and CTMS) generated notification to the concerned entities (Importer, Freight forwarder, C&F agent and supplier).
It is seen from the research of BUILD that implementation of Pre-Arrival Processing (PAP) provisions can cut the average release time by eight (08) days, it means that full implementation of PAP, introduction of system-generated notification for IGM submission can improve the situation.
Introduction of commonly agreed risk analysis and sampling techniques for improving customs and other agency controls through improved collaboration among all agencies involved in consignment clearance process will be helpful for identifying those declarations that require detailed examination to avoid overlap and waste.
Presently the time for consignment released by AEO takes 13 days 5 hours on the other hand Non-AEO consignment release takes 13 days 13 hours. Presently NBR is working for awarding ten more AEOs those who have VAT compliance software. However if the time requirement is almost same for AEO and Non-AEO what is the benefits of AEO policy, ultimate need is to reduce time for releasing consignment.
Service providers for releasing consignments face critical problem to identify assigned focal Customs officer for the process which is one of reasons for delay. Uploading real-time examination data in the ASYCUDA World with detailed of the assigned person will be helpful. Introduction of system-generated notification/text message to importers/ service providers (freight forwarders, C&F Agent) after completion of assessment and customs valuation is another way to reduce the delay.
TRS itself suggested some recommendations which if implemented could show better result in future. Arranging motor vehicles and walkie-talkie system in the examination/jetty area for smooth movement and communication is another solution.
Establishing integrated testing facilities for all certification agencies near the port is vital. Installing more scanners and integrating scanning systems in the ASYCUDA World, full implementation of the electronic payment system to expedite e-payment through (RTGS) gateway of Bangladesh are important. Integration and accessibility of BEPZA, BIDA, BEZA, BSCIC, BSTI, BAEC, Plant Quarantine, and Fisheries and Livestock and High-tech Park Authority in the ASYCUDA World is also very important.
In case of air cargo consignment, the port authority should eliminate the requirement of submitting a signed Air Way Bill (hardcopy), rather virtual approval could work. It can reduce the release time by one day. Electronic endorsement of AWB by customs needs to be incorporated in ASYCUDA and CTMS (Container Terminal Management System). Enforcement of mandatory submission of IGMs before the departure of aircraft from the origin can be avoided. It could be submitted electronically to the Customs and can be shared with port authority through CTMS.
Elimination of signature on assessment notice by using Barcode scanner synchronized with ASYCUDA could be a policy. Elimination of document checking at the delivery Gate, ASYCUDA data should be synchronized with CTMS and port database in real time, manual data entry in the delivery register of Customs and ports can be avoided as all the information are available in ASYCUDA system.
A Full-fledged electronic system for uploading documents, implementing the requirement for a Customs Post Clearance Audit function, establish connectivity or an interface for Customs with the Chittagong Port Authority cargo management system are some of the priorities already identified.
Example of EDI method following example of other countries can be established for filing truck manifests in advance of the arrival of the truck. All the suggestions of the study on TRS for reducing consignment releasing time needs to be implemented phase-wise to see a better outcome of upcoming TRS.
Ferdaus Ara Begum, CEO and Md Nuruzzaman, Research Associate of BUILD- a Public Private Dialogue Platform.
