Link below, as well as full story.
Service providers have no control over containers on border hold
In May 2002 the Government announced ‘The Protecting Our Borders’ program to help control
illegal movement of people and goods while at the same time ensuring law abiding citizens and
traders suffer minimal disruption as they go about their business at the border. Since this time
container x-ray has become an accepted and integral element of the logistics chain.
The facts for importers and your logistics service providers
Why Container X-ray is important and necessary?
Container X-rays improve the Australian Border Force (ABF) capacity to detect prohibited goods,
including illicit drugs and illegal firearms that may be illegally shipped in containers. They also help
identify non compliance with import and export requirements. The container selection process is not
random. Selection is intelligence driven and based on risk. Current Container Examination Facilities
(CEF) operations indicate that the number of imported containers subject to x-ray is approximately
101,500 TEU and physically examine around 14,000 TEU each year.
Where are CEF’s currently located?
The four major CEFs are located in Sydney, Melbourne, Brisbane and Fremantle. These facilities
house container x-ray machines capable of x-raying up to four sea cargo containers at a single time.
There are also smaller CEF’s in Adelaide, Newcastle, Darwin, Launceston, and Townsville. CEF’s allow
ABF to inspect a significant amount of cargo coming into Australia.
The Container Selection and Inspection Process screens and risk assesses all import and export cargo
and will select around 7% of loaded import containers for inspection at the CEFs. Empty containers
and export cargo are inspected where there is an identified need to do so and of all these containers
approximately 10% are subject to further examination based on the analysis of X-ray images.
Critical components of the process
In accordance with the Customs Act, ABF require a cargo reporter to report all goods that they have
arranged to be carried to Australia 48 hours prior to vessel arrival in most cases. Late reporting
means the inspection process may commence late, take longer and this may result in additional
storage and related costs from container terminal operator(s) (CTO).
Who is responsible for cargo reporting to ABF?
The shipping company and sub manifest reporter is responsible for reporting the contents of each
container. As container examination is intelligence driven, detailed information is critical to process
CTO’s currently provide three days free storage for containers once they are declared available after
discharge of the vessel. ABF endeavours to return all containers from the CEFs so that it can be
collected without the importer incurring storage charges, however, this is not always possible due to
a variety of regulatory and CTO requirements.
An arrangement has been negotiated with the stevedores where containers selected for ABF
intervention will receive a minimum of 24 hours free storage when they are returned from the
Container Examination Facility, subject to particular conditions. Importers should note that in some
locations stevedores operate 7 days a week / 24 hours a day for receipt and delivery and the 24 hour
free storage period may apply in those locations on a Saturday or Sunday.
To ensure that your cargo will qualify for the additional free storage arrangements if it is selected for
ABF intervention, ABF recommends that all required documentation is provided at least 24 hours
prior to the arrival of the vessel at the port of discharge. This will allow ABF time to have finalised its
risk assessment and meet the terms for access to the additional free storage arrangements.
If you report later than these suggested timeframes, ABF cannot ensure that you will be eligible for
the additional free storage arrangements. For more information on the storage arrangements refer
to Sea Cargo Status – Service Levels ACCA # 2012/18.
While time slots can be booked in the CTO’s vehicle booking system prior to the cargo being cleared
by ABF, it is a commercial reality that this process is dependent upon booking container receival
slots in advance.
Where slot bookings are made prior to ABF release to try and facilitate a speedy cargo turnaround,
you become exposed to additional costs occurred from the cancellation of the slot time and
subsequent cascading costs involving both transportation and labour time.
Understanding the challenges experienced by your logistics service provider
“Your logistics service provider has no control over the compounding effects of the sea cargo
logistics chain when CEF intervention occurs”.
This chain is complex and requires as far as possible integration of regulatory agencies, CTO’s and all
other parties involved in the cargo logistics delivery chain.
The links within the logistics chain include:
Predictability in ABF container release
Vehicle booking system time slots availability
Transport and importer availability
CTO operational patterns
ABF – CEF’s operational patterns
It only takes one of these links to become out of step to disrupt the entire cargo logistics delivery
chain process. Many of these issues are outside the control of, and are not the direct responsibility
of, your logistics service provider. As such additional costs involved are a result of government policy
and CEF intervention and unfortunately will be to the importers account.
What is the impact on your business?
Delays gaining access to cargo, the possibility of extra storage and subsequent CTO and
transportation charges could be incurred for the reasons explained within this article.
While ABF and their contracted service providers should exercise appropriate care for all cargo, it is
good business practice to ensure you have arranged for the appropriate packing and insurance of
goods. Any claims for damages and storage, where there is evidence to suggest this has arisen as a
result of the CEF activities should be directed to the Compliments, Complaints and Suggestions to
If you are making a complaint or seeking compensation from ABF regarding the importation of goods
which have been subject to a Border Hold, please complete the online feedback form. All claims
must be made using this form.
What can importers do?
As the challenges involved with the CEF process have arisen from government policy there is little
that can be done to avoid the issues detailed. You can, however, take note of the possibility of ABF
CEF intervention as part of your normal operations and liaise carefully with your logistics service
provider who will continue to facilitate your cargo release and communicate with you throughout
the CEF process.
An option available for importers is to consider becoming an Australian Trusted Trader which is a
voluntary trade facilitation initiative. It recognises businesses with a secure supply chain and
compliant trade practices, rewarding accredited businesses with a range of trade facilitation benefits
including priority trade service, differentiated examination and access to dedicated Account
Manager. Perhaps ABF may provide more predictability of sea cargo status at the border as part of
the differentiated examination benefits to Australian Trusted Traders.
The International Forwarders and Customs Brokers Association of Australia Ltd. (IFCBAA) has been
actively involved in Container and Cargo Examination Facilities (CEF) related issues since the
commencement of CEF operations in 2002 and has worked on behalf of its members with ABF to
review the concerns relating to delays in cargo release and the impact on the trading community
since the introduction of the CEFs.
It has become evident that to achieve an operationally viable practice on behalf of the trading
community, an increase in public awareness of the associated issues and subsequently an increase in
pressure on relevant stakeholders to ensure predictability in container release and continuous
process improvement is necessary.
These challenges in the border clearance process are a result of the intervention of the ABF CEF
process and the inherent lack of predictability in container release. These requirements are outside
the control of your logistics service provider and are the direct result of government policy. The
additional costs created from the compounding effects of CEF intervention are NOT because of or
indeed the responsibility of your logistics service provider.
For more information about the IFCBAA visit our website www.ifcbaa.com
Head of Border and Biosecurity
19 August 2021