As of January 4th, could ACI supplementary be filed by the origin forwarder prior to LOADING and the destination forwarder file the eManifest prior to ARRIVAL? Would there be a penalty for not filing prior to loading?

As of January 4th, could ACI supplementary be filed by the origin forwarder prior to LOADING and the destination forwarder file the eManifest prior to ARRIVAL? Would there be a penalty for not filing prior to loading?

As of January 4th, 2021, it is mandatory to transmit the eHBL data set and the Close Message data set at least 24 hours prior to loading the vessel at the last port of departure before Canada. Both data sets may be filed up to 90 prior to loading. Between January 4th and June 4th, 2021 there will be notices of non-compliance and possibly zero-rated AMPs issued. After June 4th, 2021 AMPs penalties will be issued if all secondary is not filed within the timeframes.