THE Association of International Shipping Lines (AISL) has voiced strong opposition to the Bureau of Customs’ (BOC) proposed In-Transit Asset Management and Supervision System (ITAMSs), warning that the mandate could slap the industry with billions in additional costs while failing its primary regulatory purpose.
In a position paper submitted to the BOC on March 17, the AISL argued that the ITAMSS framework is fundamentally misaligned with the objectives of Customs Administrative Order (CAO) 08-2019, which mandates the monitoring of the 90-day dwell time for foreign containers. The association pointed out that while dwell time is legally measured from the date of discharge until re-export, the ITAMSs focuses exclusively on tracking empty containers after they have cleared customs and left the importer’s warehouse.
The shipping group noted that the system’s monitoring process begins only after containers have already left the port, raising serious questions regarding the platform’s ability to effectively track the total stay of a container in Philippine territory. Furthermore, the AISL highlighted that the system’s scope appears narrow, as industry data suggests that roughly 70 percent of empty containers are returned directly to port terminals from warehouses. This leaves only 30 percent moving to the off-dock depots that the ITAMSs aims to monitor, further diluting the system’s intended impact on regulatory oversight.
A primary point of contention is the proposed P850 booking fee per container, which the AISL estimates would translate to an annual P2.6-billion increase in logistics expenses. The group cautioned that these costs would likely cascade through the supply chain, hitting importers, local industries, and consumers at a time when global trade is already reeling from high fuel prices and geopolitical instability in the Middle East.
Beyond the financial impact, the AISL flagged several operational risks, including new requirements for appointment booking and electronic seal assignments that could severely hamper truck turnaround times and create bottlenecks in the movement of empty containers.
Technical vulnerabilities were also cited as a major concern, specifically the potential for GPS signal disruptions or device malfunctions in the congested streets of Metro Manila to trigger false system alerts and unnecessary investigations. The association further questioned whether the BOC conducted a mandatory Regulatory Impact Assessment (RIA) under Republic Act 11032, or the Ease of Doing Business Act, to determine if the regulation imposes an undue administrative burden. Given these issues, the AISL urged the BOC to set aside the ITAMSs and instead revisit the Automated Container Movement Monitoring System (ACMMS). This “GoFast” solution, discussed in 2023, offers a comprehensive end-to-end monitoring solution at no cost to the government or the transacting public while ensuring efficient space allocation at depots.