TIME RELEASE STUDY

2018
KOLKATA CUSTOMS PORT
COMMISSIONERATE
 FOREWORD
Kolkata Customs (Port) Commissionerate has carried out its second Time Release
Study (TRS) for the period 1-7 July, 2018. The first TRS was carried out for the
entire year of 2017 and published on 14th February 2018. TRS and its publication is
one of the important objectives of the National Trade Facilitation Action Plan
(NTFAP) 2017-20. TRS serves to inform the various Government Agencies and Trade
about the areas in which they can bring about reduction in time taken for processing
and clearance of import & export cargo. In this TRS it has been found that importers
are taking inordinately long to make duty payments and register their goods for
Customs examination whereas Customs is processing imports in 90% cases within
one day. The delay by importers is the main reason for high release time noticed for
Kolkata Port which is 8.5 days average. This is much higher than the target set by
NTFAP which is 3 days for import cargo and also compares unfavourably with other
major ports. The TRS however also depicts positive trends and areas where action if
taken by importers and other stakeholders especially Customs Brokers and Partner
Government Agencies (PGAs) can bring down release time appreciably, e.g., AEO
enrolment and Direct Port Delivery (DPD) facility use and filing of Advance Bill of
Entry. The Single Window Interface for Facilitating Trade (SWIFT) has to be more
effectively used by PGAs. In fact importers who are operating under any of these
three facilities can expect to get their consignments cleared within the target of 3
days. This is one major finding and learning point from the TRS.

This TRS has also covered exports and there the release time is much better as
expected. However, there is still much scope for improvement and bring down the
average time to 2 days as targeted by the NTFAP. This can happen if more exporters
operate under the RFID e-sealing procedure so that they can avail of the Direct Port
Entry (DPE) facility.

Kolkata Customs (Port) will shortly take further actions on the TRS findings aimed to
bring down the cargo release time to acceptable levels. Importers and exporters on
their part are advised to apply for AEO status, use DPD facility, file Advance Bill of
Entry and operate under RFID e-sealing (exports).

Manish Chandra
Commissioner of Customs (Port)
2
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
 INDEX

S. Page
Content
No. No.

Team 4

1 Summary 5-6

2 Introduction- Objectives and Methodology 7-9

3 Kolkata Port Performance 10

4 Import Procedure 11-13

Analysis of Import Data- Categorisation by Bills of Entry,

5 14-29
Live Tracking of Bills of Entry and Role of PGAs

6 Export Time Release 30-33

7 Conclusions and Recommendations 34-36

8 Disclaimer 36

3
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
 TEAM

Customs:

Shri Manish Chandra, Commissioner of Customs (Port)

Shri M. A. Ansari, Additional Commissioner of Customs (Port)

Shri Amarendra Narayan, Additional Commissioner of Customs

Shri M. L. Shukhpal, Additional Commissioner of Customs (Port)

Shri Vivekanand Maurya, Deputy Commissioner of Customs (Port)

Shri A.R.V. Demta, Assistant Commissioner of Customs

Shri I. Ahmed, Appraising Officer

Shri Subrata Debnath, Superintendent of Customs (Preventive)

Shri Kalyan Chowdhuri, Examining Officer

NIC:

Shri Rajib Sarkar, Scientist D

4
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
1. SUMMARY:
This study presents the findings of the Time Release Study (TRS) 2018 conducted at
Kolkata Custom Port Commissionerate in respect of both import and export cargo,
for which Bills of Entry and Shipping Bills were filed in the first week of July 2018.

TRS 2018 was conducted as a sensitization cum learning exercise involving all
stakeholders unlike in 2017 when it was a post statistical analysis. The TRS of 2017
is published in the Kolkata Customs Website (http://www.kolkatacustoms.gov.in).

The study has accessed various data sources, including Customs, Port Terminal,
Container Freight Stations (CFS) and survey based live tracking of Bills of Entry and
Shipping Bills. Small sample surveys have been attempted to identify micro level
behavioural issues of different stakeholders.

TRS 2018 is an in house effort, involving officers of Kolkata Custom House aimed at
developing capacity building for future study.

1.1 IMPORTS:
The sample period for the study was the first seven days of July 2018, so as to
provide strictly comparable release time data.

The study has covered all the 1828 Bills of Entry filed during the sample period and
tracked them till August 7, when the data was frozen for analysis.

The standard definition of release time is the time taken from arrival of
the goods (represented by Entry Inward of vessel) to release of cargo by
Customs (represented by grant of out of charge).

Two separate sample studies have been conducted to quantify the time from
berthing of the vessel to grant of Entry Inwards (47 minutes) and from ‘Out of
Charge’ given by Customs to ‘Gate Out’ by the Importers/Customs Brokers (31
hours), identifying the reasons for delay in gate out.

The all-in-one average release time for imports has improved from 223.2
hours (9.3 Days) in 2017 to 206.73 hours (8.5 Days) in 2018.

5
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
The Bill of Entry with minimum release time of 9.88 hours was characterised by the
four features that must be at the core of drive to reach National Trade Facilitation
Action Plan (NTFAP) target of 72 hours. These are (a) higher share of Advance Bills
of Entry, (b) greater facilitation, (c) more AEO enrolment, (d) higher DPD
clearances.

The average release time for Advance Bills of Entry was 183.32 hours (7.6 Days) vis-
a-vis 250.13 hours (10.4 Days) for Normal Bills of Entry. Despite of this obvious
benefit, only 64.95% of the Bills of Entry were filed before the arrival of goods
(Advance Bill of Entry).

The overall facilitation level with no examination was 90.86%. Percentage of 1st
check came down to 1.72% during this TRS from 30% recorded in the last quarter
of 2018.

The total number of DPD Bills of Entry was only 38 with average release time for
DPD Advance facilitated Bills of Entry at 61.00 hours (2.5 days). This is well within
the target of 72 hours set by the NTFAP.

1.2 EXPORTS:
The Export release time has been calculated from filing of the Shipping Bill to
Customs Let Export Order and the average release time is 76.32 hours or 3.18 days.
The time taken from filing of Shipping Bill to departure of vessel has also been
calculated and found to be 108.14 hours or 4.5 days. Total number of Shipping Bills
filed during the TRS period was 2144. There is significant variation in the average
export release time, with export release time of 83.75 hours (3.4 days) for Frozen
Shrimps and 156.66 hours (6.5 days) for Aluminium Sheets coming from
neighbouring states.

The methodology adopted for computation of export release time for some live
cases separately involved data collection and analysis in respect of five major
commodities namely (i) Frozen shrimps, (ii) Aluminium Sheets, (iii) Jute (iv) Tea
and (v) Leather goods to ascertain item specific release time.

This study has presented a set of recommendations for achieving NTFAP goal of 72
hours for import cargo and 48 hours for export cargo.

6
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
2. INTRODUCTION – OBJECTIVES AND
METHODOLOGY:
2.1 INTRODUCTION:
Presently, Trade Facilitation and enforcement effectively go hand in hand. It is thus
important to include technology augmentation and Integrated Risk Management as
effective strategies. Intensive engagement between the regulatory authorities and
trade with trust based approach is a step in this direction. The Indian vision of trade
facilitation is aimed at transforming the trade ecosystem by reducing the time and
cost of doing business. This is intended to be achieved by further simplification of
procedures, easy access to all trade related information, use of technology and
infrastructure augmentation. National Trade Facilitation Action Plan (NTFAP) has set
a goal of reducing the average release time for import goods to within three days for
sea cargo and within two days for air cargo and ICD and on the same day for Land
Customs Stations. Similarly, the goal for release of export goods is below two days
for sea cargo and on the same day for air cargo, ICD and LCS.

2.2 OBJECTIVES OF TRS:

ü Spreading awareness about time release among all stakeholders and their
role in its reduction. This was the primary motivation for conducting ‘live’ TRS
ü Measuring distance to National Trade Facilitation Action Plan target of release
time of three days for import of sea cargo and two days for export of sea
cargo
ü Identifying category of Bills of Entry, commodities and sub-processes that are
relatively more time-consuming, with a view to suggest measures to improve
time releases relating thereto
ü Improving coordinated border management by seeking to approximate
release time associated with different prominent agencies
ü Assessing impact of statutory and administrative changes on trade behaviour
over time and identify reasons for non-compliance through sample survey
among outliers
ü Capacity building by involving incumbent officers.

7
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
2.3 METHODOLOGY:

Data source: This study has expanded the data source to include data obtained from
Customs IT System, Port Terminal Operating System, CFS and special purpose
surveys including live tracking of Bills of Entry.

2.3.1 CATEGORISATION:
This is a study of stratified sample of cargo categorised on the basis of Bills of Entry,
wherein a single Bill of Entry may cover more than one container or goods covered
by more than one Bill of Entry stuffed in one container (LCL cargo). The average
release time for all Bills of Entry has been calculated for the Facilitated and Non-
Facilitated Bills of Entry. The release time for Advance and Normal Bills of Entry has
been separately calculated under the sub-heading Facilitated/Non-Facilitated. The
methodologies to calculate release time for these categories of Bills of Entry are
different.

2.3.2 DEFINITION OF RELEASE TIME:

The Release Time in this study is defined as the time taken from the grant of Entry
Inward to grant of out of charge by Customs in respect of both, Normal Bills of
Entry, wherein the Bill of Entry is filed after grant of Entry Inward, as well as
Advance Bills of Entry, wherein the Bill of Entry is filed before the grant of Entry
Inward. Therefore, in the case of Advance Bills of Entry, the time taken between
filing of Advance Bill of Entry and grant of Entry Inward has been ignored by setting
the same to zero in respect of each such Bill of Entry. Similarly, the time taken in the
sub processes that are fully completed before grant of Entry Inward is assumed as
zero.

2.3.3 LENGTHENING THE TIMELINE:

Sample study was conducted in respect of all 41 vessels that berthed at various
terminals of Kolkata Dock System including Netaji Subhash Dock and Haldia Dock
Complex during the TRS period.

8
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
At the other end of the process chain, a sub study was conducted covering eleven
Container Freight Stations (CFS) to quantify the time taken by trade after being
given out of charge till gate out from the Container Freight Station premises. It is
seen that during study period it took about 8 hours on average for exit from CFS
after granting Out of Charge by the Customs.

2.3.4 STUDYING THE SUB-PROCESSES:

The time lines for various sub-processes are available in the Indian Customs EDI
Systems (ICES) and they have been collated to quantify the time taken in different
sub-processes.

2.3.5 STUDYING IMPACT OF MAJOR STATUTORY AND

ADMINISTRATIVE CHANGES:
The result of this TRS has been studied to highlight the impact of certain changes:
ü time of filing of Bills of Entry
ü utilization of DPD (Direct Port Delivery) facility
ü utilization of DPE (Direct Port Entry) facility

The basic objective of the study is to quantify the release time of July, 2018 and in
order to provide context and relevance of these numbers, the release times have
been compared with those of 2017, wherever available.

9
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
3. KOLKATA PORT PERFORMANCE:
Kolkata Port is the first major port and the only riverine port of the country.
Commissioned in 1870, the port faced a steady decline since 1966-67, with
competition from neighbouring sea ports and the challenges of river drafts, bends
and bores and lock restrictions proving a growing deterrent for larger ships to visit
the docks. However, it continued to re-engineer itself in diversifying its functions and
handling the increasing volumes.

Kolkata Dock System, one of the Port’s twin dock systems and the continuing legacy
of the historic port of Kolkata, handled an all time high cargo traffic of 17.39 Million
Tonnes in 2017-18 while Haldia Dock Complex, sister dock, too handled 40.496
Million Tonnes in 2017-18, sustaining a consistent growth trend of traffic in last few
years. In container traffic too, Haldia Dock Complex notched a high growth of
14.87% in 2017-18 over 1,35,828 TEUs (Twenty feet Equivalent Unit) handled in last
fiscal year. Kolkata Port (NSD) has handled 7,96,210 TEUs in 2017-18, clocking an
over 3.18% growth vis-à-vis last year. Together with Haldia Dock Complex Kolkata
Port Trust aims to achieve 1 Million TEUs throughput in 2018-19.

The ‘Act-East Policy of the country, which includes, connecting of the Trilateral
Highways, interconnecting five river systems, Kaladan project which proposes to
connect KoPT with Sittwe port of Myanmar through sea, transhipment of Bangladesh
cargo etc., is expected to contribute in making Kolkata a dynamic hub port of the
region again. Kolkata Customs, as before will contribute to provide all possible
assistance in this regard to KOPT and Trade.

BASCULE BRIDGE AT KOLKATA PORT

10
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
4. IMPORT PROCEDURE
The standard import clearance process can be largely categorised into various stages
commencing with filing of Import General Manifest (IGM) by the shipping lines. It is
followed by electronic submission of Bills of Entry. The Bills of Entry which are files
after grant of Entry Inwards of the vessels are known as Normal Bills of Entry.

The Customs Act, 1962 also provides the facility for filing Bills of Entry within thirty
days of expected arrival of the vessel. These Bills of Entry, which are filed before the
grant of Entry Inward, are called Advance Bills of Entry. Filing of Advance Bills of
Entry enables initiation and processing of documents even before the arrival of the
goods, thereby resulting in the reduction of the release time.

Considering the importance of early filing of Bills of Entry in reduction of release

time, the provisions of Section 46 of the Customs Act, 1962 were amended vide
Finance Act, 2017 to prescribe that the importer shall file a Bill of Entry before the
end of the next day following the day (excluding holidays) on which the vessel
carrying the goods arrived at Customs station. The law also provides for imposition
of charge for late filing of Bill of Entry without sufficient cause for such delay. This
TRS seeks to study the impact of the aforesaid amendment in the provisions relating
to filing of Bills of Entry by comparing the present data with that of 2017.

The self assessed Bills of Entry, whether Advance or Normal, after submission by
importer are processed by the automated Risk Management Systems (RMS). It is the
RMS which essentially decides whether Bills of Entry will be facilitated, i.e. the self
assessment by the importer is accepted as such or it merits verification by the Group
officers and examination by the Docks officers. In case where, the Bills of Entry are
facilitated by RMS, the importer proceeds to make the duty payment and thereafter
register the goods for subsequent out of charge. These Bills of Entry are called
facilitated Bills of Entry.

11
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
4.1 DIRECT PORT DELIVERY:
The Direct Port Delivery (DPD) facility has been extended to selected importers and
the facility of direct clearance of cargo upon obtaining out of charge from the Port
Terminal is available to those Bills of Entry filed by DPD clients and facilitated by
RMS. Kolkata Customs Port Commissionerate has issued Public Notice No. 04/2018
dated 12.01.2018 and PN No. 68/2018 dated 13.07.2018 on DPD and extended the
facilities to all Govt entities and over 130 other importers with proven track record.

DPD Bills of Entry constitute a sub set of facilitated Bills of Entry. Since out
of charge is given at the Port Terminal itself the goods are not required to be moved
to CFS for registration and out of charge. It is, therefore, expected that the release
time for such Bills of Entry would be significantly lower.

Among the non facilitated Bills of Entry, there are two categories:

a) First; those are selected for assessment only. In this case, the Bill of Entry is
assessed by the respective Assessing Group to which it belongs, and
thereafter the goods are taken for registration after payment of Customs
duty. After carrying out final inspection of documents, the subject goods are
given out of charge by the Dock officer

b) Secondly; where a Bill of Entry is selected for both assessment and

examination. In this case after assessment and duty payment is over, an
examination of goods, based on an examination order by Assessing Group
officer/System instruction is carried out. Thereafter if the goods are found to
be as per declaration by the Dock officer the subject consignment is given out
of charge

12
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
4.2 FIRST CHECK BILLS OF ENTRY:
There are certain categories of cargo, namely, 2nd hand machinery, certain
chemicals, textiles, food items, drugs, highly sensitive items (designated as those
which are prone to mis-declaration and evasion) which undergo a procedure called
1st Check. As the name suggest the goods are first examined by the Dock officer
and based on his report and certain other parameters like test reports, certificates
etc. the goods are assessed by the respective Assessing Groups. After assessment,
Customs duties are paid and the goods are given out of charge by the dock officer.
These Bills of Entry are called 1st Check Bills of Entry. First Check Bills of
Entry have been kept out of purview in determining the average release time as
these are rare cases where examination is carried out first. A separate analysis has
been carried out to determine the release time in such First Check cases which is
found to be 476.26 hours (more than 19 Days) and share of 1st check Bills of Entry
during the study period was 1.72%.

13
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5. ANALYSIS OF IMPORT DATA-
CATEGORISATION BY BILLS OF ENTRY:

5.1 ALL-IN-ONE: CONSOLIDATED DATA FOR ALL BILLS OF

ENTRY:
The National Trade Facilitation Action Plan (2017-20) published by National
Committee on Trade Facilitation (NCTF) envisages bringing down the overall import
cargo average release time to 72 hours for sea cargo. To ascertain the position of
Kolkata Customs in respect to the goal set up by NCTF average release time for all
Bills of Entry filed during the sample period has been calculated. It is seen that
average release time for all Bills of Entry filed during the period from January, 2017
to December, 2017 was 223.2 hours .The overall release time for 1828 Bills of Entry
for the sample period of 2018 covered by this TRS has improved to 206.73 hours
(8.6 Days).

Release
Time in 24 48 72 96 120 144 168 192 216 240 264 288 312 336 360
Hours

No. of 14 26 73 193 334 445 690 910 1056 1176 1292 1370 1438 1523 1575
B/E

14
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
It can be seen that 37.75% of the Bills of Entry were cleared within 168 hours (7
days).

15
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.2 THE EXCLUDED BILLS OF ENTRY:
During the study period, 1897 Bills of Entry were filed. Of these, 69 Bills of Entry
accounting for 3.64% of the total Bills of Entry filed were excluded for the purpose
of calculation of the average release time.

The reasons for exclusion are:

ü 29 Bills of Entry were not registered for Customs examination by Importers

ü 13 Bills of Entry were not granted Out of Charge within 30 days of unloading

ü 27 First Check Bills of Entry were studied separately

16
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.3 FASTEST BILL OF ENTRY DURING THE SAMPLE PERIOD:
The study identified the Bill of Entry that was cleared during the study period with
the minimum release time. The Advance Bill of Entry No. 7037382 dated
02.07.2018, was filed by M/s Krishna Tissues Pvt. Ltd. (AEO), which was cleared as
a facilitated Bill of Entry, with no assessment or examination, had an impressive
release time of 9.88 hours only.

The fastest Bill of Entry was characterised by the three essential features namely

ü Filing of Advance Bill of Entry

ü RMS facilitation of the Bill of Entry

ü Clearance of goods under AEO/DPD scheme

The release time in respect of these categories of Bills of Entry are discussed in the
following sub-sections.

STAGE WISE TIME ANALYSIS FOR THE FASTEST BILL OF ENTRY

Stage Wise Time Analysis for the Fastest BE

Sr. No. Stages Stakeholders In Hours %

1 Arrival to Registration Importer/CB 9.66 97.77%

2 Registration to out of charge Customs 0.22 2.23%

Release time 9.88 100 %

Share of time taken by Customs in the total release time =2.23%

17
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.4 ADVANCE BILLS OF ENTRY
Filing of Advance Bills of Entry enables the processing of documents before the
arrival of cargo, thereby saving the time in its release after arrival at Customs Port.
Recognising the importance of encouraging the trade to file Advance Bills of Entry,
Kolkata Customs has been conducting outreach programme since 2017. As a result
the share of Advance Bills of Entry has increased from 57.4% during 2017 to
64.23% during the sample period of July, 2018.

No. OF ADVANCE BILLS OF ENTRY NO. OF NORMAL BILLS OF ENTRY

1186 (64.88%) 642 (35.12%)

AVERAGE RELEASE TIME: ADVANCE BILLS OF ENTRY

The average release time of Advance Bills of Entry is 183.32 hours or 7.6 days.

18
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.5 FACILITATED VS NON FACILITATED BILLS OF ENTRY:
Increasing the level of facilitation has been one of the objectives of the Risk
Management System of CBIC. There are different grades of facilitation provided
under the RMS, with the lowest risk category being cleared on the basis of self
assessment by the importer, without subjecting the cargo to either assessment or
examination. Those Bills of Entry selected by RMS for assessment but not for
examination are also treated as facilitated. The level of facilitation has increased
from 47% in 2017 to 90.86% in this TRS.

Advance Advance Non- Normal Non-

Normal Facilitated
Facilitated Facilitated Facilitated
1067 594 118 49

Total No. of Facilitated Bills of Entry: 1661 (90.86%)

Total No. of Non-Facilitated Bills of Entry: 167 (9.14%)

19
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.6 STAGE WISE TIME ANALYSIS OF ADVANCE FACILITATED
BILLS OF ENTRY

STAGES FOR ADVANCE FACILITATED BILLS OF ENTRY

Sr. No. Stages Stakeholders In Hours %

1 Arrival to Payment Importer/CB 70.31 39.07%

2 Payment to Registration Importer/CB 101.48 56.40%

3 Registration to OOC Customs 8.15 4.53%

179.94
Release time (7.5 days) 100%

Share of time taken by Customs in the total release time = 4.53% or 8.15 hours

20
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.7 STAGE WISE TIME ANALYSIS OF NORMAL FACILITATED
BILLS OF ENTRY

STAGE WISE TIME ANALYSIS OF NORMAL FACILITATED BILLS OF ENTRY

Sr.
Stages Stakeholder In Hour %
No.

1 Arrival to Submission Importer/CB 46.67 18.95%

2 Submission to Assessment Customs 3.32 1.35%

3 Assessment to Duty Payment Importer/CB 75.17 30.52%

4 Payment to Registration Importer/CB 109.71 44.55%

5 Registration to OOC Customs 11.39 4.63%

246.26 Hours
Release time (10.6 Days) 100%

Share of time taken by Customs in the total release time = 5.98% or 14.7 hours

21
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.8 STAGE WISE TIME ANALYSIS OF NORMAL NON-
FACILITATED BILLS OF ENTRY:

STAGE WISE TIME ANALYSIS OF NORMAL NON-FACILITATED BILLS OF

ENTRY
Sr.
Stages Stakeholder In Hour %
No.
1 Arrival to Submission Importer/CB 39.72 13.53%

2 Submission to Assessment Customs 103.14 35.12%

3 Assessment to duty Payment Importer/CB 68.56 23.35%

4 Payment to Registration Importer/CB 67.2 22.89%

5 Registration to OOC Customs 15.02 5.12%

Release time 293.64 (12.5 Days) 100%

Share of time taken by Customs in the total release time = 40.24% or 4.9 days

22
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.9 STAGES FOR ADVANCE NON FACILITATED BILLS OF ENTRY

STAGES FOR ADVANCE NON-FACILITATED BILLS OF ENTRY

Sr.
Stages Stakeholders In Hours %
No.
Arrival to Payment Importer/CB 46.32 21.65%
1
Payment to Registration Importer/CB 160.52 75.03%
2
Registration to OOC Customs 7.11 3.32%
3
Release time 213.95 (9 days) 100%

Share of time taken by Customs in the total release time = 3.32% or 7.11 hours

23
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.10 DPD VS. NON DPD
Direct Port Delivery (DPD) facility of Kolkata Customs, is being implemented in close
cooperation with all stakeholders, to reduce the release time and improve the ease
of doing business. The facility allows cargo to be given out of charge directly from
the Port Terminal, thereby eliminating the requirement of containers being moved to
CFSs for the purpose.

It is a matter of satisfaction that the average release time target of 72 hours under
National Trade Facilitation Action Plan has been significantly bettered at 52.13
hours in respect of Advance facilitated DPD Bills of Entry. The study recommends
that promotion of DPD scheme should continue to be at the core of efforts by
Kolkata Customs to reduce the release time. Kolkata Customs Port Commissionerate
has issued Public Notice No. 04/2018 dated 12.01.2018 and PN No. 68/2018 dated
13.07.2018 on DPD and extended the facilities to all Govt entities and over 130
other importers with proven track record. However, the response from importers has
been poor with only about 40 importers availing the facility during this TRS period.

Percentage of containers cleared under DPD facility was 33.39 for the month of July,
2018.

24
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.11 FIRST CHECK ANALYSIS:
The 1st check Bills of Entry involve maximum release time, which is inherent in the
process.

The study shows that the average release time for 1st check Bills of Entry was
476.26 hours (19 Days 20.26 Hours) and share of 1st check Bills of Entry during the
study period was 1.72%.

Average Release Time: Advance vs. Normal Bills of Entry in First check
cases
Advance Normal
467.99 Hours (19 Days 11.99 Hours) 520.92 Hours (21 Days 16.92 Hours)

25
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.12 TIME SHARE IN IMPORT PROCESS AT CFS (ENTRY
INWARD TO EXIT OF GOODS FROM CFS)
A sub study was conducted covering eleven Container Freight Stations (CFS) to
quantify the time share in import process at CFSs. The study was conducted on the
basis of live survey and data available at CFS’s system.

Entry Inward to 3.6 Days

arrival at CFS
Arrival to 5.2 Days
Registration
Registration to 7.5
Out of Charge Hours
Out of Charge 8.00
to out gate Hours
Total time 9.4 Days

It is seen that considerable time is taken for movement of container from Dock to
CFS though introduction of CFS Gate Module vide Public Notice No. 07/2018 dated
23.01.2018 made the process seamless. The reasons for such delay are:
a) There is restriction imposed by the State Authority for movement of heavy
vehicle in roads connected to Dock and CFSs.
b) Entry Inward of vessel is granted immediately on arrival of vessel but in most
cases the vessels are initially berthed at idle berth and subsequently shifted to
working berth after 14.4 hours. Therefore, there is on an average 24 hours
delay in unloading of containers after arrival of vessel at Dock.

26
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.13 LIVE TRACKING OF BILLS OF ENTRY-FINDINGS
The live tracking of limited numbers of Bills of Entry was considered with multiple
objectives. It was intended to estimate the time taken in processes which do not
bear specific stamp in the system, including those which involved PGAs. For the
purpose of live tracking, the study relied on the Customs Brokers, who were
requested to provide data relating to their Bills of Entry, as per prescribed pro-forma
/ questionaire.

The survey was initiated with distribution of 200 pro-forma to different Customs
Brokers. However, at the end of the study period, only 145 filled up pro-forma
returned to the TRS team.

After excluding the Bills of Entry that appeared to suffer from variour infirmities,
110 Bills of Entry were found to be available for analysis.

The average release time for these 110 Bills of Entry was 198 hours (8days) vis-a-vis
206 (8.6 days) for all 1828 Bills of Entry covered for the study.

The result of the live survey are consistent with the release time seen for the entire
sample Bills of Entry, with Advance Bills of Entry returning release time better than
the Normal Bills of Entry. Similarly, facilitation resulted in signficant reduction in the
release time. The release time for Advance facilitated Bills of Entry under live
tracking was 52.13 hours which is lower than the release time of 179.94 hours for
the full sample data. However, in view of the possibility of a selection bias in the Bills
of Entrry covered by the live tracking and the findings that many Bills of Entry
referred to PGAs had to be excluded because of incomplete information, the study
decided not to take credit for the lower release time arrived at through the live
tracking of Bills of Entry.

The study, however, is of the view that the live tracking of Bills of Entry did serve
the objective of spreading awareness regarding the importance of and issues
associated with minimising the release time.

27
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.14 THE ROLE OF PARTNER GOVERNMENT AGENCIES:
The role of Partner Government Agencies (PGA) in the clearance of import cargo is
crucial. CBIC has introduced SWIFT to bring all PGAs on one platform for providing
single documentation facility as well as common Risk Management System.
However, considering certain allied norms, different procedures are prescribed with
ultimate responsibility of ensuring their compliance on Customs. Clearance for such
goods can be under both facilitated as well as second or first check, depending on
the conditions imposed on their importability and risk profile. The release time of
such cargo is expected to be considerably longer in comparison to cargo which
doesnot require no objection cetificate from respective PGA. The impact on release
time of cargo in cases requiring NOC from PGAs has been studied and the findings
are as below:

5.14.1 Food Safety and Standards Authority of India (FSSAI):

The total number of Bills of Entry refered to FSSAI was 75, accounting for 4.1% of
total Bills of Entry. The average release time for these Bills of Entry was 242.73
hours (10 days).

The following salient points need to be highlighted:

a. The release time in respect of FSSAI is significantly higher

b. FSSAI has a significant footprint in Customs clearing process, with

diverse commodity profile

c. NOC was not given in SWIFT by FSSAI in allmost all the cases and
they provided hard copy of NOC instead. The CB produces the NOC to
Assistant Commissioner(Dock/CFS) for entry in the ICES after
verification of the NOC from FSSAI website. The entire process takes
almost two days

5.14.2 Wildlife Crime Control Bureau (WCCB):

The study found that only one Bill of Entry during the study period required no
objection from WCCB. The release time in respect of this Advance facilitated Bill of
Entry was 281.51 hours (11.73 days). It is also observed that the importer took 10
days for registration of goods after payment of duty.

28
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5.14.3 Assistant Drug Controller (ADC):

Under the Drug and Cosmetics Act, the regulation of manufacture, sale and
distribution of drugs is primarily the concern of the State Authorities while the
Central Authorities are responsible for approval of new drugs, clinical trials in the
country, laying down the standards of the drugs, control over the quality of imported
drugs, coordination of the activities of State Drug Control Organisations and
providing expert advice with a view to bring about uniformity in the enforcement of
the Drugs and Cosmetics Act. During the sample period, only two Bills of Entry were
referred to ADC. The average release time in respect of these Bills of Entry was
173.85 hours (7.23 days) only.

5.14.4 Plant Quarantine (PQ):

During the sample period, 75 Bills of Entry, accounting for 4.1% of all Bills of Entry
were referred to PQ purpose. The average release time in respect of these Bills of
Entry was 245.21 hours (10 days). It is seen that NOC was not given in SWIFT by
PQ in allmost all the cases and they provided hard copy of NOC. The CB produce the
same to Assistant Commissioner Dock/CFS for entry in the ICES after verification of
the NOC from PQ website. The entire process takes almost two days.

29
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
6. EXPORT TIME RELEASE:
The importance of minimising release time for export cargo is as important as for
import cargo. The National Trade Facilitation Action Plan envisages regular Time
Release Study for export cargo through sea ports and other Customs formations.
The action plan has set the release time target for export of sea cargo to be within
two days (48 hours). In order to benchmark the current performance of Kolkata
Customs against the said target, TRS 2018 has included the Export Time Release
Study.

The data obtained from the Customs System shows that 2144 Shipping Bills were
filed during the study period of seven days from 01.7.2018 to 07.7.2018 taking the
Export Release Time from filing of Shipping Bill to Let Export Order.

It is found that the average export release time during the period of this TRS 2018
has improved to 3.2 days from the 3.9 days found during the TRS of 2017.

30
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
6.1 ANALYSIS OF EXPORT DATA:
The average Release Time from filing Shipping Bill to granting of Let export Order
(LEO) for the study period was found to be 76.32 hours (3.18 days).

Release Time in Hours <1 1-2 2-4 4-6 6-8 8-11 11-21
Day Day Days Days Days Days Days
No. of Shipping Bills
`29 46 808 387 163 24 47

6.2 RFID E-SEALED CONTAINER VS NON RFID CONTAINER:

RFID E-SEALED CONTAINER 2874 74.3 %

NON-RFID CONTAINER 994 25.7 %

74.3% of all export containers were brought to the Port Terminal under Direct Port
Entry (DPE) facility by availing RFID E-sealing (self sealing) and which were cleared
well within the average export release time of 3.18 days as such cargo are not
routed through CFS which takes extra time of about 14 hours on account of
additional movements and CFS processes.

Considering the limited utility of the time stamps in ICES, to calculate total time
span for completion of export process starting from departure of export cargo from
exporters premises to sailing of vessels this study has been conducted to quantify

31
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
the export release time by analysing real time data obtained through representative
sample.

A separate study was therefore conducted in respect of a few Shipping Bills to

calculate the net release time in export process starting from departure of export
cargo from exporter’s premises to sailing of vessels. The findings are as follows:

6.3 TIME SHARE IN EXPORT PROCESS (DEPARTURE FROM THE

EXPORTER’S PREMISES TO SAILING OF VESSEL):

Filing to 26.16 Hrs

assessment
Assessment to 57.84 Hrs
Registration
Registration to 8.88
LEO Hrs
LEO to sailing of 41.3 Hrs
vessel
Total Hours 134.18 Hrs

The study found that the average export release time, in respect of 110 Shipping
Bills, from the time of departure of export cargo from the factory gate to the sailing
of the vessel from port was 108.15 hours. As shown in the table below, the average
release time for different commodities vary from 83.75 hours for Frozen Shrimps to
156.66 hours for Aluminum Sheets.

Frozen Leather Aluminum

COMMODITIES shrimp Tea goods Jute sheets

Release time 83.75 87.95 101.52 110.85 156.66

It is seen that release time for Frozen Shrimp and Tea is significantly less than other
commodities. This is the effect of Direct Port Entry facility extended to the exporters
of Frozen Shrimp and Tea even if they are not eligible for RFID E-Sealing (Self
Sealing) facility.

32
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
6.4 TIME TAKEN INSIDE PORT TERMINAL:

Entry of goods to Registration 12.25 Hrs 19.64%

Registration to LEO 8.88 Hrs 14.21%
LEO to sailing of vessel 41.33 Hrs 66.17%
Total 62.46 Hrs 100%

33
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
7. CONCLUSIONS AND RECOMMENDATIONS:
1. As observed the overall release time is 8.5 days and 90% of all Bills of Entry
were facilitated, meaning, there were no examination done for these majority of
imports. In all such cases Customs took only 8 to 15 hours in their processing
depending on whether the Bills of Entry were Advance or Normal. However, it still
took 7.5 days for imports under Advance Facilitated to 10.25 days under Normal
Facilitated Bills of Entry to be finally cleared. The delays were in late payment of
duty (70 hours approx), late registration of goods (101-110 hours) by the importers.
Importers are seen to be poorly organized and lacking in proper planning and
strategy for early release of their cargo. If they were well prepared in filing their Bills
of Entry on time, payment of duty after System (RMS) assessment and registered
their goods on the same day, in vast majority of such cases, the target of National
Trade Facilitation Agreement Plan (NTFAP) of clearance within 72 hours would have
been achieved.

2. It is also to be noted that Kolkata Dock System being a riverine port the
vessels are called inside Dock during high tide and berthed at idle berth and
subsequently shifted to the Working Berth. During the TRS period about 87% of
total vessels were initially berthed at Idle Berth and Entry Inward for the vessels are
granted after boarding at Idle Berth. It takes about 14 hours for shifting of vessels
from Idle Berth to Working Berth. Therefore, net release time should be 14 hours
less than the time stamp captured in the System (Entry Inward to Out of Charge)
because the unloading starts on shifting of the vessel at Working Berth.

3. In the case of non facilitated imports which is cleared in between 09-12 days
importer is taking 175 hours to 207 hours i.e., 7 to 9 days for filing of Bill of Entry,
payment of duty and goods registration. If they planned well and carried out their
functions on time, even for such non facilitated Bills of Entry, clearance would have
been effected in between 3 to 5 days.

4. The performance of Customs in case of non facilitated imports has to improve

in its assessment function where 103 hours or 4.3 days was taken on average. This
is far from the average time of 24 hours expected for such cases. A special attention
will have to be given in this area.

34
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
5. Kolkata Port is the only major riverine port in the country with capacity and
infrastructure constraints. The constraints known and also ascertained during the
live TRS Survey are (i) inadequate transport facility, (ii) insufficient examination/
inspection area (Shed) (iii) inadequate RTG crane for loading. It may therefore not
be possible to achieve the target of 72 hours soon but as first step towards that an
overall target of cargo release within 7 days, i.e., within one week is achievable in
short span of time. This is the target that Kolkata Customs would first try to achieve
within this financial year. In order to achieve this target Kolkata Customs (Port) will
continue to engage with importers and advise them to follow strategies which will
guarantee fast release of cargo or assured RMS facilitation namely filing of Advance
Bills of Entry, enrolment as AEO and if not eligible for AEO, then to operate under
DPD.

6. There are only 18 importers/exporters that have enrolled as AEO under

Kolkata Customs and 13 applications for AEO under process. The first target is to
have 100 AEOs operating in Kolkata Port. Commissioner of Customs (Port) has
written personalized letters to top 200 exporters and importers in June-July this year
informing about the benefits of AEO and advising them to apply. Kolkata Customs
(Port) Commissionerate has issued Public Notices Nos. 51/11 dated 01.9.2011,
43/12 dated 26.11.2012, 67/16 dated 09.8.2016, 07/17 dated 08.3.2017 and 47/18
dated 30.5.2018 on the AEO facility.

7. The other option to importers in case they are ineligible for AEO status is to
operate under Direct Port Delivery (DPD) facility which has been extended by
Kolkata Customs Port Commissionerate to all government, public sector entities and
over 130 importers. Public Notice No. 04/2018 dated 12.01.2018 and PN No.
68/2018 dated 13.07.2018 have been issued by Kolkata Customs (Port)
Commissionerate extending this facility. However, here also response from importers
has been poor with only 40 importers availing this facility in July this year, i.e., in the
month of TRS. DPD allows for cargo release within 48 hours in case of Advance
Facilitated Bills of Entry. In view of Kolkata Ports Infrastructural constraints which
make it difficult to arrange transport and clear cargo within 48 hours, the increase in
DPD clearance time from 48 hours to 72 hours may be considered which should
allow more DPD clearances within that time.

35
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018
8. The average release time for the live tracked 110 Bills of Entry was 198 hours
(8days) vis-a-vis 206 (8.6 days) for all 1828 Bills of Entry covered for the study. This
shows that the data obtained from the system and and used was reliable as the
two different release time are closely approximate.

9. Finally the overall export release time has been found to be 76.32 hours or
which is higher than the NTFAP target of 48 hours or 2 days. Export facilitation is
94.50% and RFID E-sealed container is 76.04 %.

It is expected that with more exporters adopting RFID E-Sealing which will allow
Direct Port Entry (DPE) the overall export cargo release time can be brought down
to less than 72 hours/3 days in the near future and followed by achieving the target
of 48 hours/2 days in 1 to 2 years time.

10. It is observed that the time stamp captured by the System is 12.07 PM of the
date on which the Entry Inward is given in the System by the proper officer
irrespective of actual time of event. This results in incorrect release time calculation
by around 12 hours (maximum). DG Systems, CBIC will be requested to resolve this
anomaly.

8. DISCLAIMER:
The TRS team has made every effort to ensure that the compilation and calculation
of information in this report is accurate. However, the TRS team of Kolkata Customs
Port Commissionerate does not accept any responsibility or liability for error of facts,
omissions, interpretation, or opinion that may be present, nor for the consequences
of any decisions based on this information.

36
KOLKATA CUSTOMS (PORT)-TIME RELEASE STUDY 2018