Automated Manifest System (AMS)

The Automated Manifest System (AMS) is how U.S. Customs and Border Protection (CBP) receives manifest data electronically. For ocean freight, 19 CFR 4.7(b)(2) requires the incoming carrier to transmit the electronic equivalent of the vessel's Cargo Declaration (CBP Form 1302) through "the CBP Automated Manifest System (AMS) or any electronic data interchange system approved by CBP to replace the AMS system". CBP now processes manifests in the Automated Commercial Environment (ACE); its documents call the ocean side ACE Ocean Manifest, ACE eManifest - Ocean or the ACE Sea Automated Manifest System. Carriers and forwarders still call the filing AMS.

The 24-hour rule

CBP must receive the cargo declaration 24 hours before the cargo is laden aboard the vessel at the foreign port (4.7(b)(2)). The clock runs from loading, not from sailing or from arrival in the US. Bulk cargo, and break bulk cargo covered by an exemption CBP has granted, is due 24 hours before the vessel arrives in the US instead; any containerized cargo on those vessels still follows the 24-hours-before-loading rule (4.7(b)(4)).

Who files: the carrier or the NVOCC

Under 4.7(b)(3), an NVOCC that delivers cargo to a vessel carrier may transmit the cargo declaration for that cargo directly to CBP if it is licensed by or registered with the Federal Maritime Commission and holds an international carrier bond. If it does not, it must fully disclose the data to the vessel carrier, which files it. An NVOCC like Airlift therefore either transmits its house bills' manifest data itself or hands it to the ocean carrier to file. An NVOCC that elects to file and fails to do so properly may be liable for liquidated damages of $5,000 per violation under its international carrier bond (19 CFR 4.7a(f) and 113.64).

This is why a consolidated shipment is manifested in two layers. At the master bill level the NVOCC can appear as shipper and consignee. On each house bill, the shipper must be the foreign vendor, supplier or manufacturer and the consignee the party receiving the goods in the US; the NVOCC, forwarder or consolidator is not acceptable there (19 CFR 4.7a(c)(4)).

What the manifest must show

Among other elements, 19 CFR 4.7a(c) requires:

• The last foreign port, the first foreign port where the carrier takes possession of the cargo, the voyage number and the scheduled date of arrival at the first US port
• The carrier's Standard Carrier Alpha Code (SCAC). Each bill of lading number starts with the four-character SCAC of the carrier or issuer, followed by up to 12 characters
• Quantities at the lowest external packaging unit: a container holding 10 pallets of 200 cartons is manifested as 200 cartons
• A precise description, or the 6-digit HTS number, and the weight. "FAK", "general cargo" and "said to contain" are not acceptable descriptions
• The shipper's and consignee's names and addresses. On a bill made out "to order of" a named party, that party is reported as consignee, and any other commercial party listed for delivery or contact goes in the Notify Party field

AMS vs ISF

Both are due 24 hours before loading abroad, but they come from different parties. The manifest is the carrier's or NVOCC's account of the shipment it is carrying. The Importer Security Filing (ISF) is the importer's, or its agent's, data on the commercial side: seller, buyer, manufacturer, country of origin and HTS number (19 CFR 149.3). The ISF is filed at the lowest bill of lading level, normally the house bill, so the bill number on the ISF must match the one the NVOCC manifests.

Air cargo

Air manifests are also transmitted electronically. Under 19 CFR 122.48a the inbound air carrier must send cargo data to CBP by set times before arrival; certain other qualified parties may elect to send part of it: an ABI filer (the importer or its customs broker), a container freight station or deconsolidator, an express consignment facility, or the air carrier that arranged the transport (122.48a(c)). A subset, the Air Cargo Advance Screening (ACAS) data, must reach CBP before the cargo is loaded on the aircraft.

Common mistakes

• Vague descriptions such as "general cargo", or a carton count that doesn't match the packing list
• The forwarder named as shipper on a house bill instead of the actual foreign seller or manufacturer
• Shipping instructions sent after the documentation cut-off, leaving no time to transmit before the 24-hour window closes

For ocean imports into the US, see ISF filing and FCL ocean freight.