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NEW CUSTOM HOUSE, MUMBAI ZONE-1
TIME RELEASE STUDY
01-15 JANUARY 2019
A Customs Release Time Study Based on WCO & CBIC Guidelines
NEW CUSTOM HOUSE, MUMBAI ZONE-1 Central Board of Indirect Taxes & Customs
Ministry of Finance - Department of Revenue - Govt. of India
TABLE OF CONTENTS
Glossary ……………………………………………………………………………….…….………...5 Message from Chief Commissioner, Mumbai Zone-1
……………………………………………………………………………….……………... 8
1. EXECUTIVE SUMMARY ........................................................................................................... 9 1.1 Introduction and Context
1.2 Purpose and Objective 1.3 Guidelines of WCO & CBIC
2. SCOPE & METHODOLOGY ………................................................................................................ 13
2.1 TRS Sample Size 2.2 The WCO’s TRS Measure 2.3 Methodology Followed
2.4 TRS Timeline& Approach
3. RESULTS & ANALYSIS ......................................................................................................... 21 3.1 Measurement of Release Time
3.2 Analysis of Import Clearance Data 3.3 Release Time for Total Bs/E 3.4 Release Time for Facilitated Bs/E
3.5 Release Time for Non Facilitated Bs/E 3.6 Release Time for Advance/Prior Bs/E
3.7 Release Time for Normal Bs/E 3.8 Release Time for First Check Bs/E 3.9 Release Time for Second Check Bs/E
3.10 Release Time for Bs/E of AEO Clients 3.11 Release Time for Facilitated Bs/E of AEO
3.12 Release Time for Facilitated Advance Bs/E of AEO 4. EXPORT TRS
.........................................................................................................40 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
TRS (1-15 January) 2019, NCH, Mumbai Customs 4
5. FINDINGS OF RESULTS
……………………………………….…........................................................ 48 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
6. LESSON FROM OUTLIERS
……………………………………….…......................................................... 63 6.1 Listing Out of Outliers 6.2 Stage-wise Summary of Outliers
6.3 Case Study of Top Outliers 6.4 Case study-I (BE-9551051 Dt. 07.01.2019) 6.5 Case study-II (BE-9527330 Dt. 04.01.2019)
6.6 Case study-III (BE-9537478 Dt. 05.01.2019) 6.7 Case study-IV (BE-9627339 Dt. 14.01.2019)
6.8 Lesson Learnt From Outliers 6.9 Measures Taken To Improve Release Time in Recent Past
7. ICD MULUND TRS ……….................................................................................................76
7.1 Analysis of Data & Release Time for Import Clearance 7.2 Release Time For Total Bs/E
7.3 Release Time Distribution For Total Bs/E 7.4 Analysis of Group Wise Release Time 7.5 Analysis of Export Release Data
7.6 Release Time For Facilitated & Non-Facilitated SBs 7.7 Release Time For Inspected & Examined SBs 7.8 Analysis of LEO to EGM Time
8. PERFORMANCE ANALYSIS OF MUMBAI PORT (MbPT) ………................................................................................................84
8.1 Introduction & Profile 8.2 Performance Highlights for FY 2018 8.3 Comparative Performance Analysis
9. CONCLUSION & DISCLAIMER ………………………………...………..........................................................87
9.1 Conclusion 9.2 Disclaimer 9.3 Acknowledgement
TRS (1-15 January) 2019, NCH, Mumbai Customs 5
GLOSSARY
AEO (Authorised Economic Operator) A party involved in the international
movement of goods in whatever function that
has been approved by Custom as complying
with WCO or equivalent supply chain
security standards.
Advance or Prior B/E B/E filed prior to (maximum 30 days of)
arrival of vessel.
Bill of Entry (BE or B/E) Declaration submitted by importer or broker to Customs for approval of importing the goods.
Bill of Lading Document issued by a Shipping Agency to
the exporter and importer detailing the cargo on-board. Contains similar information as the manifest.
Bulk Cargo Bulk cargo is commodity cargo that is
transported unpackaged in large quantities. It refers to material in either liquid or granular, particulate form, as a mass of relatively small
solids, such as petroleum/crude oil, grain, coal, or gravel.
CHA/Custom Broker(CB) One who authorised by importers/exporters to prepare and process Bills of entry or
Shipping Bills, arrange customs payments, and represent the importer or exporter in Customs matters.
Custodian
Exporter
When imported goods are brought into Customs area, until an order of clearance is
made by the proper officer of customs, the goods are taken care of by an authority
approved as a custodian.
In relation to any goods at any time between
their entry for export and the time when they are exported, includes any owner,
beneficial owner or any person holding himself out to be the exporter.
FCL/LCL Full Container Load/Less than Container Load
TRS (1-15 January) 2019, NCH, Mumbai Customs 6
Facilitated B/E B/E not required Custom-intervention in
respect of assessment or examination or
both.
Importer In relation to any goods at any time
between their importation and the time when they are cleared for home consumption, includes any owner,
beneficial owner or any person holding himself out to be the importer.
Import General Manifest (IGM)
Document issued by a carrier to customs officials detailing the cargo, passengers,
and crew on board. Contains similar information as the Bill of Lading.
In-bond B/E Refers to goods for which the Importer decides to hold off making entry upon
arrival and issue a bond to Customs in lieu of payment of duties. These goods can either move to another port within the
country or be held in a bonded warehouse for up to 30 days, at which point entry
must be made and duties paid.
Let Export Order (LEO) When Customs clears an export consignment
to release for export from India.
Out of Charge (OOC) When Customs clears an import consignment
to release.
Partner Government Agency
(PGA)
Indian Government entity other than Customs
with an interest in clearance of international trade to the country.
Port of arrival Port where a specific shipment first arrives on Indian soil.
Port of entry Port where Importers/CBs submit entries for
a specific shipment.
Port of unloading Port where a specific shipment is unloaded
from theinternational conveyance.
ROSL Export Promotion Scheme by Govt of India to
provide Rebate of State Levies (ROSL) on
inputs including packaging, fuel, duty on
electricity generation and duties and charges
TRS (1-15 January) 2019, NCH, Mumbai Customs 7
on purchase of grid power, as accumulated
through the stages of production from yarn
to finished garments.
SakshamSeva Single point helpdesk for ICES/Network/
Hardware related issues for departmental
Users.
Shipping Bill (SB or S/B) Declaration submitted by exporter or broker to Customs for approval of exporting the goods.
Shipping/Carrier Agency Who physically moves the goods from export Country to Import Country’s port ofentry.
Time to release Time required for release of import (Entry
Inward to out of charge) or export
(Registration to LEO). Trade
Refers to the private entities involved in
importing goods to India, particularly importers, exporters, and their
representatives.
Vessel Seagoing craft capable of transiting
international cargo.
Warehouse B/E B/E cleared to store goods in custom bonded
warehouse without payment of duty. Duty is to
be paid at the time of ex-bond.
X-Bond B/E B/E filed to clear goods stored in warehouse.
TRS (1-15 January) 2019, NCH, Mumbai Customs 8
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
Message from Chief Commissioner
Mumbai Zone-1
TRS (1-15 January) 2019, NCH, Mumbai Customs 9
1
1.1 INTRODUCTION AND CONTEXT
A Time Release Study (TRS) is a method endorsed by the World Customs
Organization (WCO) to measure the Customs performance in trade
facilitation. A TRS principally looks at how quickly the imported cargo and
that to be exported is released by Customs. The time required to release goods
(from entry inwards to grant of out of charge) has also increasingly become
the measure by which the international trading community assesses the
effectiveness of the countries in trading across Borders.
The present study is an analytical report conducted on the clearance process
of Import and Export cargo between the 1st of January 2019 to the 15thof
January 2019 by Mumbai Customs, Zone-I.The data from ICES and DG
System has been taken to analyse the clearance of bills of entry and shipping
bills. It maps the present clearance times with that of the corresponding
period of past two years, i.e. 2017 & 2018 to plot the progress made.The
study covers the 1044 Bills of Entry filed during the study period and followed
their path till 23rd January 2019. It highlights the performance of this Zone’s
work and has measured and mapped the clearance process for exports and
imports while aiming to help customs officials identify specific causes of
delays at critical border crossing points and take the necessary action to
remove or mitigate such delays,thus improving overall performance of
Customs. This is the first study to be published by this Customs House.This
study was undertaken without introducing any extraneous factors to
influence the outcomes, in order to identify the specific problem areas and
suggest measures to streamline the processes.
The present study measures the relevant aspects of the effectiveness of
operational procedures carried out by Customs, other regulatory agencies and
private sector stakeholders in the standard processing of imports, exports and
in transit movements. The report brings out the average time taken for the
clearance of consignments from entry to exit in Customs area and prescribes
possible corrective measures for the Customs and other stakeholders to
improve their performance, thereby reducing the dwell time.
EXECUTIVE SUMMARY
TRS (1-15 January) 2019, NCH, Mumbai Customs 10
The TRS report brings out the fact that Customs Zone-I maintains a high level
of performance efficiency in trade facilitation and predictable delivery of
release time by processing, assessing, and clearing legitimate cargo efficiently
and effectively. However, this study also finds that handholding of the various
partners/stakeholders needs to be a focus area to improve the time taken for
clearance.
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 11
1.2 PURPOSE & OBJECTIVE
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 key objectives of the TRS are :
1. Identifying bottlenecks in the international supply chain and/or constraints affecting cargo release from Customs.
2. Assessing the efficacy of newly introduced and modified techniques, procedures, technologies, infrastructure and administrative changes.
3. Examining effectiveness of Client service charters and improving on service standards for consistent predictable & transparent release/delivery of goods.
4. Reducing clearance and processing time and to achieve efficiency for Custom, Other Government Agencies and private stakeholders.
5. Identifying opportunities for trade facilitation improvements and further reduction in release time in the jurisdiction of New Customs House, Customs Zone I, Mumbai.
TRS (1-15 January) 2019, NCH, Mumbai Customs 12
1.3 GUIDELINES OF WCO & CBIC
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:
Article 7: Release and Clearance of goods
6. Establishment and Publication of Average Release time
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 13
2
2.1 TRS SAMPLE SIZE
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.
Successful performance measures should be simple to do, simple to understand
and simple to respond to. They should be valued by those engaged in the
processes being measured, which requires that they be relevant to the local
situation.
SCOPE & METHODOLOGY
TRS (1-15 January) 2019, NCH, Mumbai Customs 14
2.2 THE WCO’s TRS MEASURE
The WCO’s TRS measure is:
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.
With the mission statement of providing leadership, guidance and
support to Customs administrations to secure and facilitate legitimate trade,
realize revenues, protect society and build capacity, it provides technical
expertise to its member countries to conduct TRS.TRShelps Customs
administrations facilitate trade based on international conventions, tools and
instruments for simplification and harmonization of Customs procedures.
The Study is stratified in steps shown below :
Plan
Collect Data
Test Validate
Identify Findings
Analysis
Calculate Results
Report
Make Recommendation
TRS CYCLE
TRS (1-15 January) 2019, NCH, Mumbai Customs 15
2.3 METHODOLOGY FOLLOWED
The Customs Zone-I, located in New Custom House, Mumbai is one of the
oldest Customs locations in the country. This study covers both import and
export release time for the NCH and ICD (Mulund).
According to WCO guidelines for conducting Time Release Study,
definition of “Release time” is the time taken from arrival of the goods
(Time of Entry Inward of vessel) to release of cargo by Customs (Time of
grant of out of charge).
The stages in the release of Imported Cargo at a seaport can be classified into
following stages:
a) Filing of Import General Manifest (IGM) by the Shipping lines.
b) Self-assessment and submission of Import declaration (Bs/E) by the
Importer/Custom Broker to the ICES (Indian Customs Electronic Data
Interchange System).
c) Uploading necessary scanned documents in ICES through e-SANCHIT.
d) Submission of the declaration data (Bs/E) from ICES to Risk
Management System.
e) Decision of the RMS to facilitate or send the Bs/E for scrutiny by
officers.
f) Decision, either at the request of the Importer or by officer, to examine
the cargo before completion of scrutiny (First Check). Decision to send
the Bs/E for examination after scrutiny (Second Check).
g) Payment of duty in respect of all facilitated Bs/E and scrutinized
second check Bills of Entry.
h) Goods registration by Importer/CB for all the Bs/E except Ex-Bond
Bs/E.
i) Examination of cargo and entry of examination report in the ICES.
j) First check Bs/E are sent back to the Assessment groups to complete
the scrutiny followed by duty payment and out of charge.
k) Collection of all documents and Out of Charge in ICES.
l) Goods released by Custodian (MbPT and CONCOR for ICD Mulund) to
Importer.
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 16
Similarly, the goods for Export go through the following stages for cargo
release:
a) Uploading necessary scanned documents in ICES through e-SANCHIT.
b) Filing of Shipping Bill in ICEGATE to Risk Management System.
c) Decision of the RMS to facilitate or scrutiny by Customs.
d) Carting of export goods to Custom Bonded Area.
e) Assessment of Shipping Bill by RMS/Customs in ICES.
f) Payment of duty by Exporter/CB in ICES, if any.
g) Registration of Shipping Bill by Exporter/CB before Customs.
h) Examination or Inspection of goods as required by Customs.
i) Release of Goods for Export (LEO) by Customs.
j) Filing of EGM by Shipping lines in ICEGATE.
k) Release of Post Export Benefits (Drawback, ROSL, IGST Refund etc.) by
Customs in ICES.
l) Credit of Post Export Benefits to registered bank account of Exporter.
TRS (1-15 January) 2019, NCH, Mumbai Customs 17
The average release time has been calculated for the following categories of
1044 bills of entry filed during the sampling period. The time taken into
account, is from the grant of entry inward to the out of charge given by the
Customs. So, even for the Advance/Prior Bs/E, the time taken for the study is
from the grant of entry inwards.
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
Commodity Wise: The average release time in respect of top import
commodities at NCH, Mumbai Zone-1, has been analysed.
Importer Wise: This was done by separating the Authorised Economic
Operators (AEOs) and the Non AEOs. This TRS report has brought out the
release time for AEO and Non-AEO importers distinctly.
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 18
2.4 TRS TIMELINE & APPROACH
BE Submission Entry inwards Goods Registration Out of Charge
Importer/CB (Trade) Dwell Time Starts Trade Goods Released
Assessment–Group/RMS Duty Payment Examination of Goods
Custom Trade Custom
Entry Inwards Assessment–Group/RMS Goods Registration Out of Charge
Dwell Time Starts Custom Trade Goods Released
BE submission Duty Payment Examination of Goods
Trade Trade Custom
TRS Timeline For an Advance BE
TRS Timeline For a Normal BE
TRS (1-15 January) 2019, NCH, Mumbai Customs 19
The methodologies below has been adopted for the TRS 2019:
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.
3. As per the WCO guidelines, measurement of performance has been
recorded in actual Customs and trade working without
special/additional measures to influence the data in any form.
4. According to System Policy, time of Entry Inward is recorded as
00.00 (12’O Clock night).
5. For a number of commodities, customs Duty payment is exempted
and therefore Such Bs/E have not been considered for calculating the
average time from assessment to payment and from payment to
registration.
6. There have been instances where due to re-assessment the duty
payment in the system is reflected as being deposited prior to
assessment as such cases distort the data and have not been
considered for arriving at average release time.
7. Following10 categories of Bs/E were made to compare with
previous two TRS -
(i) Average Time Release for Total Bs/E
(ii) Average Time Release for Facilitated Bs/E
(iii) Average Time Release for Non Facilitated Bs/E
(iv) Average Time Release for Prior/Advance Bs/E
(v) Average Time Release for Normal Bs/E
(vi) Average Time Release for First Check Bs/E
(vii) Average Time Release for Second Check Bs/E
TRS (1-15 January) 2019, NCH, Mumbai Customs 20
(viii) Average Time Release for AEO Bs/E
(ix) Average Time Release for Facilitated AEO Bs/E
(x) Average Time Release for Advance Facilitated AEO Bs/E
8. Release Time for each of above Category is divided into following 05
Phases:-
(i) Inward to Submission
(ii) Submission to Assessment
(iii) Assessment to Payment
(iv) Payment to Registration
(v) Registration to OOC
TRS (1-15 January) 2019, NCH, Mumbai Customs 21
3
3.1 MEASUREMENT OF RELEASE TIME OF
IMPORT CARGO
The Import process has already been elaborated in methodology followed,
Section 2.3 earlier. Certain administrative changes in the Customs Act,1962
have been made to expedite the clearance of the imported goods. The impact
of these has been studied and will also be a part of this report by comparing
with the previous two years. The Import General Manifest (IGM) and the
Bs/E, whether advance or normal are filed electronically in the ICES either
through the Service Centre or through ICEGATE mode. Thereafter, the same
are forwarded to the Risk Management System (RMS). The RMS processes
the Bills of Entry and the IGM, through a series of steps and generates an
electronic output for the Indian Customs EDI System (ICES), which decides
whether a bill of entry will be facilitated/partially facilitated or non
facilitated to be assessed by the Group Officers.
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.
RESULTS & ANALYSIS
TRS (1-15 January) 2019, NCH, Mumbai Customs 22
The Facilitated Bs/E are exempted either from assessment and examination
both or at least anyone i.e. assessment or examination. Therefore, RMS
Bs/E get out of charge through ICES. The Group Assessed Bs/E are divided
into two types- First Check & Second Check Bs/E. Based on the output
given by the RMS, Bs/E are directed to the assessment or examination
along with suitable instructions to mitigate the risk identified in the
declaration. The instructions are in the form of guidelines to the officers to
concentrate on various likely issues of mis-declaration, concealment,
undervaluation, mis-classification, availment of ineligible notification
benefits and violation of allied acts. First Check Bs/E follow a special type of
clearance procedure. It requires assessment twice by Group, as well as
thorough examination followed by sampling/testing of import goods and
hence, naturally takes more release time compared to other types of Bs/E.
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 23
The following chart shows the clearance process of a normalB/E :
Importer / CB
Assessmentb
yGroup
Filing of
Bill of Entry
Facilitated
BE
Duty Payment
Registration of B/E in ICES/ICEGATE
Examination
OUT OF
CHARGE
TRS (1-15 January) 2019, NCH, Mumbai Customs 24
The following chart shows the clearance process of all three types
of Facilitated B/E :
FILE B/E in RMS
No Assessment
No Examination
Only Assessment
No Examination
No Assessment
Only Examination
Importer / CB
Assessment
by Group
Duty Payment Registration &
Examination
Registration
Duty Payment
OUT OF CHARGE
TRS (1-15 January) 2019, NCH, Mumbai Customs 25
The following chart shows the clearance process of a First Check
B/E:
Importer / CB
First
Assessment
by Group
Duty Payment
OUT OF
CHARGE
Filing of
B/E
Registration &
Examination
Final
Assessment
by Group
TRS (1-15 January) 2019, NCH, Mumbai Customs 26
3.2 ANALYSIS OF IMPORT CLEARANCE DATA
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.
The number of different categories Bills of Entry is shown as under-
TYPE OF B/E NUMBER OF Bs/E (%)
2017 2018
TRS-2019
FACILITATED 151(12.3%) 83(7.6%) 94(9%)
NON FACILITATED 1073(87.7%) 1009(92.4%) 950(91%)
ADVANCE/PRIOR 466(38.1%) 396(36.3%) 372(35.6%)
NORMAL 758(61.9%) 696(63.7%) 672(64.4%)
FIRST CHECK 44(3.6%) 40(3.7%) 25(2.4%)
SECOND CHECK 1180(96.4%) 1052(96.3%) 1019(97.6%)
TOTAL AEO Bs/E 236(19.3%) 229(21%) 206(19.7%)
FACILITATED AEO 61(5%) 40(3.7%) 49(4.7%)
FACILITATEDADVANCE AEO 31(2.5%) 20(1.8%) 31(3%)
TOTAL Bs/E 1224 1092 1044
TRS (1-15 January) 2019, NCH, Mumbai Customs 27
The data sample had 1044 Bills of entry for the given period. 372 Bills of
entry filed prior/advance to filing of IGM were also considered for this study.
The following emerge when compared in %:
1. The Facilitated Bs/E have increased over the corresponding period of
last year but are less compared to 2017. While, non-facilitated Bs/E
have shown a marginal increase.
2. Advance/Prior Bs/E have decreased marginally compared to 2018 and
2017. While the normal B/E filing has shown an increase.
3. First Check Bs/E are reducing.
Now, detail analysis of results obtained for each category are being shown
below along with graphical representation in compare to results from
previous TRS:
3.3 RELEASE TIME FOR TOTAL Bs/E In this section, the average release time, in hours, for different categories of
Bs/E filed for the import Cargo in Customs Zone-I without going into the
group or commodity details is as under.The analysis is based on the
methodology elaborated (based on WCO guidelines) in Sections 2.2 and 2.3:
Sl.No. PARAMETERS TRS-2017 TRS-2018 TRS-2019
1 Inward to Submission 51.38 15.98 14.68
2 Submission to Assessment 73.06 33.09 20.63
3 Assessment to Payment 55.19 39.70 31.37
4 Payment to Registration 34.54 41.58 21.55
5 Registration to OOC 13.50 7.68 4.41
6 Total Average Time Taken 227.67 138.03 96.15
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 28
It is indeed heartening to note the consistent reduction in the dwell
time.Total average Cargo release time for all types of Bs/E together has
reduced significantly by 58% and 30% as compared to year 2017 and 2018
respectively. It shows that the NTFP times are within reach now. This report
shall present suggestions to further streamline processes for all the
participants in this effort of release of import cargo.
The time attributable to Customs is the Sl.No.2, from Submission to
Assessment and the Sl. no.5 i.e. Registration to Out of Charge (OOC). The
Sl.No. 2 also includes the time taken by the Importers to reply to queries, if
any, raised by the Customs. Effectively, theSl.No.1, partly 2, 3 and 4 are
attributable to the time by the importers in clearance of cargo. As is evident,
the Customs takes 25.04 hours (26%) of the total time while the importers
take 71.11 hours (74%) of the total time.
TRS (1-15 January) 2019, NCH, Mumbai Customs 29
3.4 RELEASE TIME FOR FACILITATED Bs/E
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission 1.62 -12.04 -9.18
Submission to Assessment 0.10 0.08 0.15
Assessment to Payment 56.38 61.40 52.08
Payment to Registration 71.10 63.87 41.18
Registration to OOC 3.09 2.60 1.12
Total Average Time Taken 132.29 115.91 80.94
(All the time shown in hours)
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%).
TRS (1-15 January) 2019, NCH, Mumbai Customs 30
3.5 RELEASE TIME FOR NON FACILITATED Bs/E
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission 58.39 18.28 17.04
Submission to Assessment 83.33 35.80 22.66
Assessment to Payment 55.02 37.92 29.52
Payment to Registration 29.39 39.75 19.90
Registration to OOC 14.97 8.10 4.73
Total Average Time Taken 241.10 139.85 97.65
(All the time shown in hours)
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 31
3.6 RELEASE TIME FOR ADVANCE/PRIOR Bs/E
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission -53.94 -64.99 -34.56
Submission to Assessment 102.66 28.48 11.29
Assessment to Payment 66.19 48.25 30.11
Payment to Registration 69.28 89.59 85.66
Registration to OOC 4.49 5.76 0.29
Total Average Time Taken 188.68 107.09 80.84
(All the time shown in hours)
The advance Bs/E have contributed to the reduction in dwell time
even though they include facilitated and non-facilitated Bs/E. Total Average
Cargo release time for Advance/Prior Bs/E has improved significantly in
current TRS. It is reduced by 57% and 25% as compared to year 2017 and
2018 respectively. Moreover, total average time in registration to OOC is also
reduced substantially by 94% and 95% since 2017 and 2018 respectively,
and presently is seen to be less than 30 minutes. However, the Bs/E filed in
this category needs to improve considerably. The advance filing helps in
cutting down the time taken in processing of the B/E after the arrival of
cargo, thus reducing the release time after its arrival. This study brings to
fore the need to conduct outreach programs as already said earlier, to
encourage the importers to avail of this facility in large numbers.
TRS (1-15 January) 2019, NCH, Mumbai Customs 32
3.7 RELEASE TIME FOR NORMAL Bs/E
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission 116.13 62.04 44.56
Submission to Assessment 54.87 35.71 20.30
Assessment to Payment 48.43 34.84 24.12
Payment to Registration 13.18 14.27 10.14
Registration to OOC 19.04 8.78 5.54
Total Average Time Taken 251.65 155.64 104.62
(All the time shown in hours)
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 33
3.8 RELEASE TIME FOR FIRST CHECK Bs/E
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission 259.16 2.81 34.08
Submission to Assessment 352.10 195.82 139.38
Assessment to Payment 27.50 30.04 15.17
Payment to Registration -239.90 -90.67 -61.68
Registration to OOC 248.30 102.87 68.32
Total Average Time Taken 647.16 240.87 197.79
(All the time shown in hours)
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 34
The B/E filed in such cases is registered with the Docks and is transferred
to the Shed Appraiser for examination of the cargo many times necessitating
engagement of experts/specialists. After examination of the cargo, the Shed
Appraiser transfers the first check Bs/E to the Appraising Group after
entering report in the EDI System. Now, the First Check B/E is assessed.
After payment of levied duty, if any, the B/E is again presented to Shed
Appraiser. The Shed Appraiser, after verifying that the levied duties are paid,
gives OOC for the said B/E. Thus, there is expected increased release time
for the cargo, but with identification of peculiar nature of requirements with
granular data of different commodities, streamlining the process may be
possible. However, as is noticed, with monitoring and certain administrative
changes, locally, the time taken by the Customs has reduced considerably
by 449.37 hours (69.5%) since 2017 and 43 hours (17.9%) since 2018.
3.9 RELEASE TIME FOR SECOND CHECK Bs/E
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission 43.64 16.48 16.57
Submission to Assessment 62.66 26.90 19.50
Assessment to Payment 56.22 40.07 30.01
Payment to Registration 44.77 46.61 22.10
Registration to OOC 4.75 4.07 3.01
Total Average Time Taken 212.04 134.13 91.19
TRS (1-15 January) 2019, NCH, Mumbai Customs 35
Total Average Cargo release time for Second Check Bs/E has improved
significantly in current TRS. It is reduced by 56% and 30% as compared to
year 2017 and 2018 respectively. In fact, it is 118.38 hours less than the
time in 2017. The time taken by Customs is 22.51 hours (24.7%) while by
the importers is 68.68 hours (75.3%) presently. As is apparent, most time is
taken in stage 3 and 4 i.e. in payment of the duties and registration of the
cargo. Sensitizing the importers about the need to reduce the time taken at
their end and increasing interaction to identify the hurdles in their payment
and registration stages will help in streamlining processes even further.
3.10 RELEASE TIME FOR Bs/E OF AEO CLIENTS
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission -24.40 -58.52 -18.62
Submission to Assessment 92.37 18.77 21.03
Assessment to Payment 36.53 40.23 41.86
Payment to Registration 75.42 105.60 49.49
Registration to OOC 2.33 4.64 1.27
Total Average Time Taken 182.25 110.72 89.58
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 36
The AEO clients are offered a basket of benefits that also include faster
clearance. Total Average Cargo release time for Bs/E of AEO Clients has
improved significantly in current TRS. It is reduced by 51% and 19% as
compared to year 2017 and 2018 respectively. The assessment times have
dropped drastically from 92.37 hours to 21.03 hours, however, the
Importers need to focus on the quick payment of duties as well as the
registration of goods which takes up 55% of the total time presently.
Moreover, total average time in registration to OOC is also reduced
substantially by 46% and 73% since 2017 and 2018 respectively and
presently stands at 1.27 hours.
Difference between total release time of Total Bs/E and AEO Bs/E
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 37
3.11 RELEASE TIME FOR FACILITATED Bs/E OF
AEO CLIENTS
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission -1.14 -27.79 -9.66
Submission to Assessment 0.10 0.11 0.17
Assessment to Payment 52.70 52.72 53.71
Payment to Registration 58.49 69.53 40.94
Registration to OOC 2.03 3.15 1.11
Total Average Time Taken 112.18 97.72 77.05
(All the time shown in hours)
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 38
3.12 RELEASE TIME FOR FACILITATED
ADVANCE Bs/E OF AEO CLIENTS
PARAMETERS TRS-2017 TRS-2018 TRS-2019
Inward to Submission -63.23 -79.71 -44.34
Submission to Assessment 0.10 0.08 0.09
Assessment to Payment 69.55 50.01 60.40
Payment to Registration 69.95 106.63 39.91
Registration to OOC 2.17 4.19 1.23
Total Average Time Taken 78.54 81.20 49.96
(All the time shown in hours)
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.
49.96
TRS (1-15 January) 2019, NCH, Mumbai Customs 39
This TRS report comes to the conclusion that the AEO client program 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 and 4 in the chart above will help in
streamlining the processes further.
TRS (1-15 January) 2019, NCH, Mumbai Customs 40
4
4.1 ANALYSIS OF EXPORT RELEASE DATA
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.
On Examination level, there are two categories- Inspection and
Examination. S/B selected for Inspection by RMS, requires only inspection
of the cargo. Goods need not to be opened or examined. While, S/B selected
for Examination, requires examination as per examination instructions
given by RMS/Assessing Officer.
Total 89% of Shipping Bills move directly to inspection/examination stage
without assessment by Customs. Only 11% of total S/Bs are selected by
RMS to be assessed by Customs.
TYPE NO. OF S/B PERCENTAGE
FACILITATED 311 89%
ASSESSED 38 11%
TOTAL SBs 349
EXPORT TRS
TRS (1-15 January) 2019, NCH, Mumbai Customs 41
Total 94% of S/Bs get LEO directly after registration in ICES. Only 6% of
total S/Bs are selected for examination by Customs. Thus, facilitation at
examination level (94%) are larger than at assessment level (92%).
TYPE NO. OF S/B PERCENTAGE
SBs FOR INSPECTION 327 94%
SBs FOR EXAMINATION 22 6%
TOTAL SBs 349
TRS (1-15 January) 2019, NCH, Mumbai Customs 42
4.2 EXPORT TRS TIMELINE & APPROACH
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.
Export Clearance involves multi-stages procedures executed by different
agencies/stakeholders. Transportation of export goods from Exporter’s place
to Custom Bonded Area takes larger time of the whole process. It is also
noticed that there is a substantial difference of time between filing of S/B in
ICEGATE and starting of movement of export cargo of goods from Exporter’s
place, which again negatively impacts overall release time of export goods.
EXPORT TRS COMPLETE TIMELINE
Customs Release Time
Total Export Release Time
TRS (1-15 January) 2019, NCH, Mumbai Customs 43
Further, filing of EGM contributes largest portion of time in whole export
clearing process. Filing of EGM is connected with Shipping Lines and in
most of the cases, EGM is filed after much later than the export of Cargo.
Taking above discussed factors with due consideration, to calculate the
actual time taken in completion of different export procedures, is a
complicated task. Instructions and guidelines issued by WCO on Time
Release Study are specifically on Import Cargo Clearance by the member
countries. Moreover, the report “National Trade Facilitation Action Plan”
speaks nothing much about the timeline (Start & End point of time) of
export clearance.
Therefore, to assess Export Release Time in most reliable and justifiable
manner, this Study is covering “Submission to LEO” time as Total Export
Release Time and “Registration to LEO” as Time taken by Custom to release
export Cargo.In addition, LEO to EGM stage is also being included and
analysed in the study to showcase complete picture of the clearance process
of export goods. Accordingly, the detailed analysis of the data received for
above two stages are being presented in tabular form as well as graphical
form.
4.3 RELEASE TIME FOR FACILITATED & NON-
FACILITATED (ASSESSED) SBs
PARAMETERS FACILITATED ASSESSED TOTAL SB
Submission to Registration 79.86 87.05 80.66
Registration to LEO 1.86 2.22 1.87
TOTAL AVERAGE TIME 81.72 89.27 82.53
TRS (1-15 January) 2019, NCH, Mumbai Customs 44
4.4 RELEASE TIME FOR INSPECTED &
EXAMINED SBs
PARAMETERS INSPECTED EXAMINED TOTAL SB
Submission to Registration 81.82 63.17 80.66
Registration to LEO 1.57 6.84 1.87
TOTAL AVERAGE TIME 83.39 70.01 82.53
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 45
4.5 ANALYSIS OF LEO TO EGM PROCESS
PARAMETERS FACILITATED ASSESSED INSPECTED EXAMINED TOTAL SB
LEO to EGM 350.64 370.80 354.38 325.22 352.56
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 46
4.6 RELEASE TIME FOR TOP EXPORT
COMMODITIES
Commodity (RITC) Submission To Registration
Registration To LEO
Total Release Time
Iron/Non alloy zinc coatedSteel sheet
of width 600 mm or more(7104900) 104.95 1.75 106.70
Railway or Tramway Passenger Coaches (86050000)
115.97 2.89 118.86
Motor Car up to 1000 CC (87032191)
20.40 2.37 22.77
Motor Car of 1000-1500 CC (87032291)
140.43 2.16 142.59
Motor Car of 1500-3000 CC (87032391)
1.69 0.42 2.11
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 47
4.7 RELEASE TIME FOR TOP EXPORTERS
EXPORTER Submission To Registration
Registration To LEO
Total Release Time
L&T Hydrocarbon 124.03 3.69 127.72
Volkswagen India 12.73 0.37 13.10
General Motors 75.69 1.95 77.64
Bombardier Transport 115.98 2.92 118.90
Tata Motors 100.94 1.64 102.58
Fiat India 191.02 2.15 192.17
Mercedes Benz 0.49 0.41 0.90
JSW Steel Coated 95.21 1.63 96.84
Mahindra & Mahindra 119.47 1.40 120.87
Jindal Saw 4.50 0.54 5.04
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 48
5
5.1 FINDINGS AND OPPORTUNITIES
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 –
TYPE OF B/E
Average Release Time (in Hrs)
2017 2018
TRS-2019
FACILITATED 132.29 115.91 80.94
NON FACILITATED 241.10 139.85 97.65
ADVANCE/PRIOR 188.68 107.09 80.84
NORMAL 251.65 155.64 104.62
FIRST CHECK 647.16 240.87 197.79
SECOND CHECK 212.04 134.13 93.66
TOTAL AEO Bs/E 182.25 110.72 89.58
FACILITATED AEO 112.18 97.72 77.05
FACILITATED ADVANCE AEO 78.54 81.20 49.96
TOTAL Bs/E 227.67 138.03 96.15
FINDINGS OF RESULTS
TRS (1-15 January) 2019, NCH, Mumbai Customs 49
The average release time for different types of Bs/E above is interesting.
Facilitated Advance AEO Bs/E top the chart of the Release Time, which
confirms successful and effective execution of trade facilitation initiatives
taken by CBIC.
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 –
• Import of all types of Scrap and few other commodities require to be
examined 100% before clearance as per CBIC circulars to ensure that no
serviceable goods/weapons/arms/ammunition are concealed.
• In some cases the test reports are essential to verify the
Grade/Purity/Specification and other physical/chemical characteristics of
some import goods to ensure proper classification, valuation and extension
of notification benefit. Hence goods are sent for testing at different
Laboratories available in various locations in India and scrutiny is
completed on the basis of test results received accordingly.
TRS (1-15 January) 2019, NCH, Mumbai Customs 50
• In the cases of Re-Import or Import for Re-Export, it is mandatory to verify
that the goods imported are the same as the goods claimed to have been
exported or are to be exported. Drawback and other export benefits availed
at the time of exports need to be calculated and reversed/paid before
permitting completion of scrutiny. Examination in such cases is completed
after 100% verification of cargo. Same procedure is followed in case of
Import for Re-Export purpose.
• All second hand/Used Machinery is examined by Customs officers along
with a Chartered engineer to value the goods before scrutiny.
5.2 TOP IMPORT COMMODITIES RELEASE TIME
PERFORMANCE
Top 20 commoditiesimported at NCH during the period January-December,
2018 are selected and CTH wise data for said 20 commodities, were called
from Saksham Seva for the period 01-15 January, 2019. Data of total 345
entries are received, which contains following 6 Top CTHs:
(i) CTH 29023000
(ii) CTH 29025000
(iii) CTH 29152100
(iv) CTH 72083740
(v) CTH 72083840
(vi) CTH 72083940
TRS (1-15 January) 2019, NCH, Mumbai Customs 51
CTH COMMODITY Average Release Time
29023000 Toluene 50.66
29025000 Styrene 14.01
29152100 Acetic Acid 53.89
72083740 Iron or Non alloy steel strip (thickness 4.75-10 mm)
28.55
72083840 Iron or Non alloy steel strip (thickness 3- 4.75 mm)
34.51
72083940 Iron or Non alloy steel strip (thickness less than 3 mm)
33.03
Average Release Time of Top 20 CTHs 72.02
(All the time shown in hours)
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.
5.3 TOP IMPORTERS RELEASE TIME PERFORMANCE
Data received from DG, Systems for the period 01-15 January, 2019, was
sorted out IEC wise and the top 10 Importers at NCH, Mumbai were selected
for further analysis. The findings of the results so obtained are as under:
TRS (1-15 January) 2019, NCH, Mumbai Customs 52
IMPORTER Registration to OOC Total Release Time
Bharat Petroleum 0.27 243.85
Hindustan Petroleum 0.31 208.11
L&T Hydrocarbon 22.51 133.24
POSCO Maharashtra 1.38 43.83
Embarkation HQ 0.13 276.02
Supreme Petrochem 0.06 14.01
Apar Industries 0.06 58.39
Indian Oil 0.05 105.06
National Petroleum 36.86 63.05
C. J. Shah & Co. 0.52 71.17
(All the time shown in hours)
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
TRS (1-15 January) 2019, NCH, Mumbai Customs 53
Customs. The whole process takes more than usual time which make the
grounds for longer Total Release Time.
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.
5.4 GROUP WISE RELEASE TIME PERFORMANCE
GROUP No. of Bs/E Submission to Assmnt Total Release Time
1 & 1A 151 12.47 89.93
2A 70 9.53 64.23
2B 117 16.51 98.62
3 140 13.85 95.83
4 180 29.86 101.43
5 61 68.79 145.62
5B 191 15.88 94.22
6 134 18.77 91.15
TOTAL 1044 20.63 96.15
(All the time shown in hours)
Group 2A handling chemicals,
has the best release time of
64.23 Hrs, whereas Group 5
handling second hand
machinery takes maximum
time in release time due to the
first check manner of
assessment mostly adopted by
them on account of the nature
of commodities handled by
them.Chemicals of Group 2A
don’t requires any time taking
procedure in general and
hence have better release time.
TRS (1-15 January) 2019, NCH, Mumbai Customs 54
5.5 GROUP WISE IMPORTER QUERY ANALYSIS
GROUP (Chapters) No. of Bs/E Total Average Query Reply Time (in Hrs)
1 & 1A (1-28) 2 128.68
2A (29,30,31,38) 1 118.10
2B (32-49 except 38) 6 112.75
3 (50-71) 4 24.48
4 (72-83) 59 35.67
5 (84) 24 53.91
5B (85-92) 18 85.99
6 (93-99) 10 12.97
TOTAL 124 50.21
(All the time shown in hours)
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 55
Group-4 is issuing highest number of queries in 59 Bs/E out of total 124
which constitutes around 48%. On the other hand, Group-1/1A is highest
Query Release Time of 128.68 Hrs in the list of Assessing Groups at NCH.
5.6 PGA WISE RELEASE TIME ANALYSIS
PGA Name No. of BE Average Release Time (in Days)
Animal Quarantine (AQ) 1 7
Central Drug Controller (ADC) 2 3
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 56
5.7 RELEASE TIME ANALYSIS FOR DIFFERENT
TYPES OF FACILITATED Bs/E
A B/E can be facilitated in 3 following ways-
- No Assessment & No Examination
- No Assessment & Only Examination
- Only Assessment & No Examination
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-
TYPE OF B/E No. of Bs/E (%)
NO ASSESSMENT-NO EXAMINATION 94(24%)
ONLY ASSESSMENT-NO EXAMINATION 300 (76%)
TOTAL FACILITATEDBs/E 394
TRS (1-15 January) 2019, NCH, Mumbai Customs 57
PARAMETERS No Assess. No Exam. Only Assess No Exam
Inward to Submission -9.18 19.01
Submission to Assessment 0.15 17.95
Assessment to Payment 52.08 31.58
Payment to Registration 41.18 23.15
Registration to OOC 1.12 2.71
Total Average Time Taken 80.94 94.82
(All the time shown in hours)
As is evident, the maximum time taken is by the importers and their
authorized Customs Brokers. Out of the total release time in both categories
Customs took 1.27 hours and 20.66 hours respectively, despite a weekend
in the sampling period while the importers have taken 84.08 hours and
73.74 hours respectively.
The above analysis confirms that the type- No Assessment & No
Examination, i.e. fully facilitated has the best release time. Majority of
Advance Bs/E fall in this category, which has helped the fast clearance.
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 58
5.8 RELEASE TIME ANALYSIS FOR BULK & NON-
BULK CARGO
TYPE OF B/E No. of Bs/E (%)
BULK CARGO 224 (21.5%)
NON BULK CARGO 820 (78.5%)
TOTAL Bs/E 1044
PARAMETERS BULK CARGO NON BULK CARGO TOTAL AVERAGE
Inward to Submission -24.89 25.49 14.68
Submission to Assessment 11.26 23.19 20.63
Assessment to Payment 30.12 31.53 31.37
Payment to Registration 78.48 14.37 21.55
Registration to OOC 0.41 5.50 4.41
Total Average Time Taken 81.59 100.13 96.15
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 59
5.9 RELEASE TIME ANALYSIS FOR WAREHOUSE
Bs/E
TYPE OF B/E No. of Bs/E (%)
FACILITATED 25(19%)
NON FACILITATED 106(81%)
AEO Bs/E 106(81%)
NON AEO 25(19%)
FACILITATEDAEO 25 (19%)
TOTAL Bs/E 131
TYPE OF WH B/E Sub. to Ass. Reg. to OOC Total Release Time
FACILITATED 0.23 0.25 55.94
NON FACILITATED 18.35 0.68 75.56
AEO Bs/E 13.89 0.64 72.69
NON AEO 19.14 0.42 68.07
FACILITATED AEO 0.23 0.25 55.94
TOTAL WH Bs/E 14.88 0.60 71.81
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 60
5.10 RELEASE TIME ANALYSIS FOR X-BOND Bs/E
TYPE OF B/E No. of Bs/E (%)
FACILITATED 123 (28%)
NON FACILITATED 320 (72%)
AEO Bs/E 355 (80%)
NON AEO 88 (20%)
FACILITATEDAEO 103 (23%)
TOTAL Bs/E 443
TYPE OF B/E Submission to Assess. Total Release Time
FACILITATED 9.6 Minutes 36.73 Hrs
NON FACILITATED 8.6 Hrs 53.89 Hrs
AEO Bs/E 6.8 Hrs 49.06 Hrs
NON AEO 4.2 Hrs 49.44 Hrs
FACILITATED AEO 10.7 Minutes 31.89 Hrs
TRS (1-15 January) 2019, NCH, Mumbai Customs 61
5.11 RELEASE TIME DISTRIBUTION BETWEEN
TRADE & CUSTOMS
TYPE OF B/E Average Release Time (in Hrs)
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%)
TRS (1-15 January) 2019, NCH, Mumbai Customs 62
Data for First Check Bs/E represents approximate values as to ascertain
exact values are not possible due to the special nature of assessment and
examination of first check cargo.
TRS (1-15 January) 2019, NCH, Mumbai Customs 63
6
6.1 LISTING OUT OF OUTLIERS
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 results so received are as under -
S. N.
BE No.
Date Stage-wise Release Time in Hrs
Inw2Sub Sub2Ass Ass2Pay Pay2Reg Reg2OOC
1 9551051 07-Jan-19 113 527 20 -311 312
2 9485487 01-Jan-19 38 508 21 23 8
3 9527330 04-Jan-19 116 167 142 97 4
4 9551477 07-Jan-19 -7 524 1 3 0
5 9654460 15-Jan-19 90 169 190 -220 239
LESSON FROM OUTLIERS
TRS (1-15 January) 2019, NCH, Mumbai Customs 64
6 9614170 11-Jan-19 283 138 29 -53 54
7 9537478 05-Jan-19 -31 47 404 3 1
8 9621109 12-Jan-19 -8 316 -200 314 0
9 9497633 02-Jan-19 16 338 41 8 1
10 9494151 02-Jan-19 14 336 24 -192 215
11 9501469 02-Jan-19 115 17 171 92 0
12 9501500 02-Jan-19 115 17 172 92 0
13 9600244 11-Jan-19 35 126 188 25 2
14 9512885 03-Jan-19 210 1 24 115 7
15 9528438 05-Jan-19 34 247 23 23 5
16 9527837 04-Jan-19 21 260 43 3 5
17 9620457 12-Jan-19 39 219 2 69 2
18 9506193 03-Jan-19 205 0 98 25 2
19 9627339 14-Jan-19 -36 1 22 342 0
20 9653780 15-Jan-19 -54 0 42 339 1
21 9608792 11-Jan-19 17 170 -1 116 3
22 9573157 09-Jan-19 -36 1 5 334 0
23 9655112 15-Jan-19 91 168 42 -72 74
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 65
6.2 STAGE-WISE SUMMARY OF OUTLIERS
STAGE No. of Bs/E Percentage
Inward to Submission 3 13%
Submission to Assessment 12 52%
Assessment to Payment 4 17%
Payment to Registration 3 13%
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 66
6.3 CASE STUDY OF TOP OUTLIERS
Out of total 23 outliers, following 04 Bs/E are being selected for detailed
study-
1. BE No-9551051 Dated 07.01.2019 : It took highest release time of
661.45 Hrs including 113 Hrs for “Inward to Submission” and 527
Hrs for “Submission to Assessment”. As the BE is taking 527 Hrs only
in one stage, its fit case for study.
2. BE No-9527330 Dated 04.01.2019 : It took total release time of
524.13 Hrs including 116 Hrs for Inward to Submission, 167 Hrs for
“Submission to Assessment” and 142 Hrs for “Assessment to
Payment”. The BE is selected for case study as it is taking 116-167
Hrs in three different stages separately.
3. BE No-9537478 Dated 05.01.2019 : It took total release time of
424.8 Hrs including 404 Hrs for “Assessment to Payment”. The BE is
selected for case study as it is taking highest time for stage-
“Assessment to Payment”.
4. BE No-9627339 Dated 14.01.2019 : It took total release time of
329.47 Hrs including 342 Hrs for “Payment to Registration”. As the
BE is is taking highest time for stage-“Payment to Registration”, it is
fit case for study.
6.4 CASE STUDY-I (BE-9551051 Dt.07.01.2019)
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.
It is seen that the B/E passed through 23 stages from 07.01.2019
(04:47PM) to 30.01.2019 (01:27PM). Each stage was handled by an
independent section as below:
TRS (1-15 January) 2019, NCH, Mumbai Customs 68
1. BE was filed in First Check Assessment.
2. BE has been processed 04 times for Assessment by Group.
3. BE has been processed 03 times for Examination or OOC by
Import Docks.
4. BE has been processed 02 times in Bank queue for duty
payment.
5. As the consignment was first time import, importer/CB has also
completed procedure laid down vide Public Notice-03/2015 for
First Time Importer.
6. Destruction of Wireless equipment on board was completed
after following due procedures on 28.01.2019.
7. Insurance Policy dated 16.01.2019 for the said consignment
was uploaded by the Importer/CB on 29.01.2019 in ICES.
8. On 29.01.2019, Group issued order for release of goods in ICES
and hence, BE got OOC on 30.01.2019 (01:27PM).
While this is an atypical case, few such imports take place every
month at NCH.
6.5 CASE STUDY-II (BE-9527330 Dt.04.01.2019)
This BE was filed for clearance of some machinery items of Chapter-
84. It was the first import by the Importer and therefore first time
import documentation was required as per Public Notice-03/2015
which was completed on 11.01.2019. On completion of this procedure,
Group has assessed the BE same day i.e. on 11.01.2019 (11:18AM).
Here is the details of movement of BE in ICES, which confirms the
above facts.
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 69
6.6 CASE STUDY-III (BE-9537478 Dt.05.01.2019)
This BE was filed on 05.01.2019 (05:21PM) for clearance of prime
stainless steel HR Coil of under HSN 72191200. BE was filed as Prior
and entry inward/finalization was done on 07.01.2019 in ICES.
TRS (1-15 January) 2019, NCH, Mumbai Customs 70
On 06.01.2019 being a Sunday, BE was assessed on very next day i.e
Monday, 07.01.2019 and sent to Bank Queue for duty payment by
Importer.
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).
6.7 CASE STUDY-IV (BE-9627339 Dt.14.01.2019)
This BE was filed on 14.01.2019 (11:45AM) for clearance of
Commercial LPG Mixture under HSN 27111900. It was a Prior B/E
and its entry inward was given on 16.01.2019 in ICES. The goods
imported were in Bulk quantity which is ascertained correctly only
after discharge is completed from vessel to tank.
TRS (1-15 January) 2019, NCH, Mumbai Customs 71
The movement details of BE in ICES is as under:
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.
TRS (1-15 January) 2019, NCH, Mumbai Customs 72
6.8 LESSON LEARNT FROM OUTLIERS
The main objective of TRS is reducing clearance and processing time
by identifying bottlenecks in international supply chain to achieve
efficiency for Customs, PGAs and private stakeholders. The Current
TRS has efficiently analyzed the release time performance of each
activity and of every stake-partner.
The findings of results obtained from performance analysis of outliers
deliver the following lessons:
LESSON FOR CUSTOMS: Although Customs performance is very
good, however, in order to reduce/improve release time of import and
export cargo, there are few area where Custom need to take more
initiatives to improve further:
1. Time Taken in Submission to Assessment for 1st Check Bs/E
2. Time Taken in Assessment of Goods imported under group-5
3. Review of Registration Procedure for Bulk Cargo
4. Reduce the time to file the B/E to 24 Hrs instead of present 48
Hrs.
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.
LESSON FOR IMPORTERS/CB: Findings of TRS are that there is a
good room for improvement for trade in respect of following area:
1. Filing Prior/Advance Bs/E
2. Time Taking in Payment of Duty after assessment
3. Time Taking in registration of Bs/E after payment of duty
4. Opting to be an AEO Client, for faster clearance of goods.
LESSON FOR EXPORTERS/CBs: Government of India is well
committed to encourage Exporters at every front. A number of Export
Promotion Schemes are already in place to promote the export from
country. This Study concludes that there is a need to reduce/improve
time attributable at the level of Exporters i.e. time taking to move
export goods from their place to Custom Bonded Area/Port after
submission of S/B in EDI, time taking to present S/B for registration
after carting of the goods.
TRS (1-15 January) 2019, NCH, Mumbai Customs 73
LESSON FOR SHIPPING AGENCIES: Findings of Export TRS speaks
out that there is big space for improvement in LEO to EGM. As on
date they are taking an average of 353 hours (around 15 Days) to
complete the process, which is not reasonable at all. The Study has
found that outreach programs and interactive sessions should be
organized with Shipping Agencies, Exporters/CBs and other
Stakeholders to make a workable plan to come down this time within
7 days followed by further improvement of the same.
6.9 MEASURES TAKEN TO IMPROVE RELEASE
TIME IN RECENT PAST New Custom House, Mumbai Custom Zone-1 has taken a number of
initiatives to improve release time of import and export cargo on local
level. Mumbai Customshas taken multiple steps towards facilitating
and securing the compliant trade by continuously striving towards
promoting the “Ease of Doing Business” and enhancing the
transparency, predictability and adaptability of the customs
procedures.
In the process of complementing the aforementioned resolution, some
of the major initiatives are mentioned and described in brief-
ENHANCED FACILITATION THROUGH RMS
Enhanced Facilitation through RMS by Simplification of RMS
Inspection Process is resulting in Reduced Time Taken for Clearance.
Facilitated Bill of Entry are those import declarations where the level
of risk is low and are cleared on the basis of self-assessment by the
importer. Such consignments are not subjected to any intervention or
examination. The level of facilitation has been increased during the
last year due to which the average release time has reduced.
DIGITIZATION INITIATIVES (Paperless &Faceless Customs)
(i) e-HELPLINE
The Customs e-HELPLINE has been created to answer queries
of the trade to provide an extra tool for faster and smoother clearance
of cargo. Importer/Exporter can access the website
http://www.mumbaicustomszone1.gov.in/eHelpline/ehelpline for
their queries which will be replied in due course.
TRS (1-15 January) 2019, NCH, Mumbai Customs 74
(ii) REGULAR MEETINGS OF (CCFC) AND (PTFC).
Meetings of high level administrative Committees i.e. ‘Customs
Clearance Facilitation Committee’ (CCFC) and Permanent Trade
Facilitation Committee (PTFC) under the chairmanship of Chief
Commissioner and Commissioner is being conducted regularly to
provide effective mechanism and cooperation to improve import &
export release time.
(iii) e-SANCHIT
This module introduces Paperless and Faceless processing
under SWIFT. This eliminates physical interface between Customs,
Partner Government Agencies thereby promoting anonymous
assessment and faster clearance. Enables the authorized persons /
customs brokers / importers /exporters to upload digitally signed
supporting documents.
TRS (1-15 January) 2019, NCH, Mumbai Customs 75
(iv) 24x7 CUSTOM CLEARANCE FACILITY
Indian Custom is providing 24x7 clearance for import as well as
export goods to facilitate just in time inventory.
(v) TURANT CUSTOM
CBIC vide its Circular No. 09/2019- Customs dated
28th February, 2019 has announced the next generation
reform “Turant Customs” for Ease of Doing Business.
Under Turant Customs significant changes have been made, as
follows-
One of the major changes will be in Indian Customs Electronic Data
Interchange System (ICES) 1.5 for clearance of imported goods after
assessment and duty payment.
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.
This obviates the necessity of importers having to present the B/E
number and date to the officer for clearance.
The officer will be able to immediately provide clearance on the
system.
Turant Customs will reduce dwell-time of the goods that are pending
only for the grant of such clearance.
TRS (1-15 January) 2019, NCH, Mumbai Customs 76
7
7.1 INTRODUCTION & PROFILE
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.
After implementation of e-SANCHIT, all the import documents at ICD
Mulund are being filed under the e-sanchit. Currently, more than 50% of
the Bills of entry are RMS facilitated with no assessment and no
examination at Mulund.
ICD MULUND TRS
TRS (1-15 January) 2019, NCH, Mumbai Customs 77
The department has appointed Container Corporation of India (CONCOR), a
Govt. of India Undertaking under the Ministry of railways, as the Custodian
of the Customs area notified. In the Year 2010, in pursuance of the Boards
Circular No 77/2009-Customs (N.T) dated 11.12.2009, the CFS Mulund was
changed to Inland container Depot Mulund (ICD), a Public notice in the said
regard was issued vide Notification No 03/2010 dated 17.03.2010 by the
Commissioner of Customs (General), Mumbai.
7.2 ANALYSIS OF DATA &RELEASE TIME FOR
IMPORT CLEARANCE
With the aim, to study and analyse the average release time of goods in ICD
Mulund, 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 are 186.
The number of different categories Bills of Entry is shown as under-
TYPE OF Bs/E NO. OF Bs/E (%)
AVERAGE RELEASE TIME (in Hrs)
FACILITATED 49 (26.3%) 258.48
NON FACILITATED 137 (73.7%) 258.68
ADVANCE/PRIOR 6 (3.2%) 118.41
NORMAL 180 (96.8%) 263.30
FIRST CHECK 13 (6.9%) 386.95
SECOND CHECK 173 (93.1%) 248.98
TOTAL AEO Bs/E 19 (10.2%) 263.88
FACILITATED AEO 14 (7.5%) 255.71
FACILITATED ADVANCE AEO 5 (2.7%) 85.75
TOTAL Bs/E 186 258.63
TRS (1-15 January) 2019, NCH, Mumbai Customs 78
7.3 RELEASE TIME FOR TOTAL Bs/E
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:
Sl.No. PARAMETERS AVERAGE TIME TAKEN (in Hrs)
1 Inward to Submission 82.14
2 Submission to Assessment 39.45
3 Assessment to Payment 80.85
4 Payment to Registration 43.33
5 Registration to OOC 12.85
6 Total Average Time Taken 258.63
The time taken by Customs is 52.3 hours (20%) while the importer’s share
in the total time is 206.3 hours (80%).
7.4 RELEASE TIME DISTRIBUTION FOR TOTAL
Bs/E
TRS (1-15 January) 2019, NCH, Mumbai Customs 79
7.5 ANALYSIS OF GROUP WISE RELEASE TIME
GROUP No. of Bs/E Submission to Assessment Total Release Time
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
TOTAL 186 39.45 258.63
(All the time shown in hours)
Group-2J with 83 Bs/E (44.6%) and Group-3 with 63 Bs/E (33.9%)
contribute together 78.5% of the total Bs/E. Total Release time taken by
Group-4 is the highest among the groups, whereas total release time taken
by Group-5A is the lowest one.
TRS (1-15 January) 2019, NCH, Mumbai Customs 80
7.6 ANALYSIS OF EXPORT RELEASE DATA
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.
Total 87.5% of Shipping Bills move directly to inspection/examination stage
without assessment by Customs. Only 12.5% of total S/Bs are selected by
RMS to be assessed by Customs.
Similarly, at examination level, Total 174 (94.5%) of Shipping Bills don’t
require Examination by Customs. Only 10 (5.5%) of S/Bs are required to be
Examined by Customs.
TYPE NO. OF S/B PERCENTAGE
FACILITATED 161 87.5%
ASSESSED 23 12.5%
TOTAL SBs 184
TYPE NO. OF S/B PERCENTAGE
SBs FOR INSPECTION 174 94.5%
SBs FOR EXAMINATION 10 5.5%
TOTAL SBs 184
TRS (1-15 January) 2019, NCH, Mumbai Customs 81
7.7 RELEASE TIME FOR FACILITATED & NON-
FACILITATED (ASSESSED) SBs
PARAMETERS FACILITATED ASSESSED TOTAL SB
Submission to Registration 55.60 61.44 56.33
Registration to LEO 3.98 2.16 3.75
TOTAL AVERAGE TIME 59.58 63.60 60.08
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 82
7.8 RELEASE TIME FOR INSPECTED &
EXAMINED SBs
PARAMETERS INSPECTED EXAMINED TOTAL SB
Submission to Registration 57.08 25.93 56.33
Registration to LEO 3.04 16.05 3.75
TOTAL AVERAGE TIME 60.12 41.98 60.08
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 83
7.9 ANALYSIS OF LEO TO EGM TIME
PARAMETERS FACILITATED ASSESSED INSPECTED EXAMINED TOTAL SB
LEO to EGM 109.69 90.55 108.27 96.79 107.61
(All the time shown in hours)
TRS (1-15 January) 2019, NCH, Mumbai Customs 84
8
8.1 INTRODUCTION & PROFILE
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.
As on today, with the development of other ports, it caters to 10% of the
country’s sea-borne trade handled by Major Ports of the country in terms of
volume. It caters about 19% of POL Traffic handled by Major Ports.
PERFORMANCE ANALYSIS OF MUMBAI PORT (MbPT)
TRS (1-15 January) 2019, NCH, Mumbai Customs 85
8.2 PERFORMANCE HIGHLIGHTS FOR FY2018
Some of the performance highlights during the last FY 2017-18 are as
under:
1. 2,27,484 units of automobiles were exported during the year 2017-
18 through Mumbai Port, which is highest in a year so far. There is a
growth of 10.66% compared to 2,05,577 units of automobile
exported during the year 2016-17. Incidentally, the total automobile
trade through MbPT with 2,29,692 units is the highest in numbers
recorded so far in a year, surpassing the volume of 2,10,179 units in
2016-17.
2. Import of POL products and Crude Oil increased by 3.75 % and
8.91 % respectively as compared to previous year.
3. Total number of cargo vessels handled at berth &
stream(anchorages) increased from 1994 in 2016-17 to 2043 in
2017-18
4. Average ship berthday output increased from 8413 tonnes in 2016-
17 to 9043 tonnes in 2017-18.
8.3 COMPARATIVE PERFORMANCEANALYSIS
Yearwise comparative performance of MbPT on important
parameters are shown as below –
Performance Indicators FY2017 FY2018 FY2019
Average Monthly No. of ships arrived
(Cargo+Non-Cargo)
452 480 440
Average Monthly No. of ships sailed after cargo
operation (excluding Stream vessels)
126 130 125
TRS (1-15 January) 2019, NCH, Mumbai Customs 86
Average Monthly Traffic (in million tonnes) FY2017 FY2018 FY2019
POL 3.05 3.14 2.34
Non-POL 2.20 2.10 1.44
Total 5.25 5.24 3.78
Container Traffic (In TEUs) 3493 3532 1770
Average time spent at berth (Days) FY2017 FY2018 FY2019
Liquid Bulk 1.38 1.40 1.40
i) POL 1.69 1.71 1.65
ii) Others 0.97 0.95 0.97
Dry Bulk 12.21 12.95 10.89
Containers 12.44 0.00 0.46
General Cargo 3.29 2.86 2.38
All Vessels 2.33 2.17 1.86
Average Turn-round time (Days) FY2017 FY2018 FY2019
Liquid Bulk 2.28 1.97 2.00
i) POL 2.79 2.33 2.30
ii) Others 1.58 1.45 1.49
Dry Bulk 17.65 13.96 11.68
Containers 12.79 0.00 0.55
General Cargo 3.98 3.38 2.95
All Vessels 3.27 2.73 2.45
Average quantum of cargo handled
per ship-day (Tonnes) FY2017 FY2018 FY2019
Liquid Bulk 18815 18791 19080
i) POL 24439 23731 23734
ii) Others 5641 5727 5393
Dry Bulk 2015 1605 1503
Containers
(i) in tonnes 1192 --- 435.00
(ii) in TEUs 13 --- 45.00
General Cargo 2337 2828 2903
All Vessels 8413 9043 10556
Avg. gangshift output (tonnes)
i) General Cargo 453.82 487.22 480.26
ii) Dry Bulk 319.66 343.85 207.96
TRS (1-15 January) 2019, NCH, Mumbai Customs 87
9
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.
In summary, the measurements show that Customs is efficient in clearing
legitimate cargo with trade facilitation. The study provides evidence that
demonstrates how Customs supports the goal of government to grow the
economy of the Country by measuring and reporting on the delivery of
service to traders engaged in international trade. Future studies will
providefurther sets of measures and evidence of actual and sustainable
change in the way Customs manages and works at the import-export
clearing cargo.
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,
CONCLUSION & DISCLAIMER
TRS (1-15 January) 2019, NCH, Mumbai Customs 88
omission, interpretation, or opinion that may be present, nor for the
consequences of any decisions based on this information.
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
We, the TRS project team as under:
1. Smt. Prachi Saroop, Commissioner, Import-I, NCH
2. Sh. J. S. Negi, Commissioner, Import-II, NCH
3. Sh. Ramesh Chander, Commissioner, Export, NCH
4. Sh. D. Behera, Asstt. Commissioner, EDI, NCH
5. D.V. Gautam, Appraising Officer, EDI, NCH
would like to thanks all Group &Docks Officers includingthose who
contributed to the TRS 2019 study (01-15 January) and in particular
acknowledge the following:
1. Mr P.V. Sudhir, Senior Technical Director, NIC New Custom House, Mumbai-I
2. Team Head & Members,
SakshamSeva, ICEGATE, New Delhi
THANKS