Situation Report On The Deployment Of UNIPASS (Integrated Customs Management Systems) On 01-04-2020

Area of Report: Takoradi

Date of Report: 27-04-2020

Report was occasioned by the numerous complaints of declarants (members).

Object of Report: To bring to the fore Issues of Inadequate Training, Seemingly Un-sequenced Process Flow and Operational Challenges.

PRELIMINARY ISSUES:

The following had engaged our attention from the onset:

1. Re-introduction of manual releases of the shipping line process.
2. The bugging issue of examination officers not being identified in the system.
3. The difficulty of registering (on boarding) on the system.

The above seems to have been resolved at the time of the visit.

PENDING ISSUES

These will be outlined in no sequential order.

1. The absence of the much promised Functional Support Service (Call Centre)resulting in walk-ins to the Operations Centre.
2. The absence or non-observance of established protocols with which to reassign jobs at the backend of customs when a named personnel who has begun a process is unavailable, renders a dead end in such circumstances.
3. There is a major issue of the lack of solution of how ICUMS should treat cargo and vehicles on a Bill of Lading. In such cases, valuation for cargo comes in minus that of the vehicle; rendering a stalled process. This could have called for amendment to separate so one could treat separately the individual items even though at additional cost. The fact however remains ICUMS has a huge issue with “AMENDMENT” as a process, making the thought of it an almost impossible option.
4. There is the matter of the repetitive use of the phrase “simple amendment” running through the remarks of officers. This has to be explained because nothing like that came up in the training sessions as to what to do; with the prevailing issues bordering on ICUM’s inadequacies in handling manifest, “simple amendment” as being requested must be thought through or halted.
5. Interesting note made of change in risk profile midway during process of one declaration. Valuation is done, accepted and duty paid. Risk selectivity shows green at one point and then moves to red on the same declaration. This is openly seen in remarks and it leaves one wondering what model is being applied and the science thereof.
6. There is a pre-entry situation which affords one the opportunity to request pre-arrival processes ie. valuation and classification, this process takes forever. We have screen shots of different transactions and the time stamps in there, tell the story. There are a plethora of declarations that began on the 9th of April and as at the 24th of April, the process is still not complete. In one particular instance, although the clearance has been done the system is still showing “examination officer” rather than “delivery allowed”.
7. The system is simply not user friendly. Declaration is back and forth and not a step by step process. Post entries are a nightmare. Interestingly this pushes the declarants to proceed physically to the operations center at the Grand Favour Hotel in Takoradi.
8. For the records, fifteen (15) declarant companies visited in Takoradi have been to the operations center out of frustration with an unresolved situation. This is easily verifiable.
9. User defined options after acceptance is restricted to only 3 items. Thus, one cannot pay interest charge which is user defined. This can and must be resolved as a systems issue because it could lead to revenue leakage.
10. One major issue identified is that of valuation. This is a serious matter which we found ran across board. The original instruction was to upload evidence of valuation done prior to 1st April 2020 when creating the Bill of Entry (BOE). It is strange however that most of these values were ignored and revised mostly downwards even to the chagrin of the declarants who feel this was an anomaly and constituted huge loss of revenue to the state but could do nothing about it! A situation can actually be confirmed where the declarant remarked in the system that value had been revised lower than the original CCVR but the appeal process itself is taking days so who would want to bother?
11. There was another specific situation where a vehicle/personal effects valuation showed a GHS1000 upward adjustment in the value of the car and a GHS2500 downward adjustment in the values of the cargo albeit the original CCVR created by the same customs had been attached for guidance. Some values already affected by the 50% reduction policy have still been revised downwards leading to ridiculously low duties. Vehicle valuation has always been standard by virtue of our unique system of valuation but several cases are replete with variations in values. This is a huge problem and will have a serious effect on revenue collection.
12. Another issue is that of our corporate administrators’ controls in the system. As at the 24th of April, administrators could not view any declaration done by their assigns unless they use the username and password of that particular assign. This is a serious anomaly. The administrator must necessarily be able to view and effect audit of every single declaration done. This means the administrator ought to have the username and password of every single assign which is simply not right. If the assign is unavailable the administrator will then not have any access to work done by the assigned.
13. The system must be interactive. Queries and answers must be seen and time stamped in the system for purposes of audit. This is not so since one can send an answer to a query and wait for days without a reply which never comes anyway.
14. There are issues regarding permits which must be looked at.
15. Every HS Code for imported wooden furniture requires a TIDD (Timber Industry Development Division) permit. Same with imported leather products, ie. Bags etc. It is an anomaly.
16. TIN (Tax Identification Numbers) could not be accessed all day on the 24th of April.
17. Three (3) companies reported Virus attack of their systems at the same time on the same day whilst processing declarations on the system and all information was wiped out immediately. Can’t confirm if this was a systems issue but has to be looked into due to the unusual coincidence.
18. An issue raised at our executive training session came up. The acceptance and rejection buttons first of all are quite close and one could mistakenly ‘accept’ when they don’t intend. Interestingly there is no pop up to ask whether you really want to accept the valuation even if it was unintended. Since this is a critical juncture. The existing situation allows for an appeal any time. There is no immediate remedy to reverse an unintended acceptance.
19. An interesting issue is that of duty difference popping up when assessed duty had already been paid. A few instances were observed ranging from GHS10, GHS70 and GHS174. The deduction is that although duty had been paid, declarations that had not been fully processed through to the following week became affected by the exchange rate of the new week. A case in point was when an aggrieved agent refused to accept this situation and had the difference in duty occasioned by this system flaw literally handed to him by one of the Korean technical expatriates. This is clearly unacceptable since duty had already been locked in place.
20. The issue of COR (Customs Offence Report) in this system is another matter. It is non-existent or cannot be seen. This is definitely at the heart of revenue. What happens when there is a short collection after examination which must trigger a post entry?
21. One flaw is the inability to load excel format invoices. If one has over 500 line item, this has to be typed and entered as such.
22. Delays in uploading of manifest onto the system was and still is an issue. It can be confirmed that not a single cargo had been cleared as on 24th April from a Grimaldi Vessel that arrived last weekend. Since no declaration can be done and manifest matched if it is not uploaded on time is a major flaw and bound to cause all the delays that we are witnessing.
23. It is interesting to note that for an end-to-end system, the EMDAs cannot be validated in the system. Declarants are still resorting to creating the permits on other platforms other than the ICUMS and effecting copy and paste on the ICUMS and for some strange reason they are accepted. eg. Ghana Standards Authority EMDA acquired from another platform ie GCNET are copied and pasted on the ICUMS and accepted. This gives rise to the creation of 2 UCRs one for the EMDA and the other for the declaration being done. This is unacceptable!!
24. We had also stressed the lack of proper training for declarants which has also led to difficulties being faced during processing of documents by declarants. The knowledge of declarants as we speak was all from a 2 hour training done in February. Most of the scenarios playing out right now had not been anticipated.
25. The call center for which we have admonished time and time again to be established is simply non-existent! Evidence of this is the trooping of our members to the operations center at Grand Favour Hotel in Takoradi. Calls to the center are ignored. We have stressed over and over again that at the center of this whole ecosystem was the Call Centre and we would not settle for less. A center with knowledgeable technical people well vexed in the system cannot be a luxury at this time. Users frustration could lead to agitation if no answers are readily provided.

CONCLUSION

It has been observed that the myriad of problems facing declarants are mostly due to the lack of proper mapping of the process flow, inadequate training of declarants and unresolved systemic issues. These have all culminated in serious delays leading to untold hardship. Demurrage and rent payments have become the norm with no respite in sight. Quality assurance is key to repose confidence in the new system. These are not normal times, the scourge of COVID-19 presents a clear and present danger to us in view of the very predictable massing up of our compatriots in search for solutions. We have seen this happen, the state will have to tarry awhile in the implementation to get all the fundamentals right. An attempt to introduce this in busier ports like KIA and Tema would be disastrous to say the least.

Edward Akrong,

President

Ghana Institute of Freight Forwarders