Filing is required by shipping lines or their delegated shipping agents, as well as freight forwarders and NVOCCs. Each filer is liable for submitting the Bill of Lading (BOL) they issue or, in the case of freight forwarders, the BOL issued by their overseas counterpart, in compliance with NAIC requirements.

Liability under NAIC applies to freight forwarders and shipping lines for meeting filing requirements in compliance with UAE law, such as submitting on time, providing complete information, and ensuring data quality. NAIC only issues penalties for non-compliance with these requirements. Any other legal violations, such as criminal offenses, are referred to the relevant authorities.

• Shipping Lines: Master Bill of Lading (MBL) for consolidated shipments or Direct Bill of Lading for direct shipments.
• Freight Forwarders: House Bill of Lading (HBL) for consolidated shipments.

When a freight forwarder consolidates shipments under another freight forwarder or an NVOCC, this can involve multiple layers of consolidation. Each issuing party must file their own Bill:

• Shipping lines file the Bill of Lading they issue.
• NVOCCs file the Bill of Lading they issue.
• Freight forwarders at each level file the Bill of Lading they issue, with the lowest-level freight forwarder filing the Bill that includes the actual consignee and shipper.

MPCI filing is required for containerized maritime cargo that is imported, transiting through, transshipped, or Freight Remaining on Board (FROB) in the UAE. FROB and transshipment filings are only required from shipping lines.

MPCI filing does not apply to export shipments, non-containerized cargo, wooden vessels, empty containers, or crew’s personal effects. These exclusions may be revised in future phases.

• Import shipments: Cargo with a final place of delivery inside the UAE.
• Transit shipments: Cargo that is discharged at a UAE seaport and transported by land or air to a final destination outside the UAE.
• Transshipment shipments: Cargo that is unloaded at one or more UAE seaports and reloaded onto another vessel before reaching its final destination outside the UAE.
• FROB shipments (Freight Remaining on Board): Cargo that arrives at a UAE seaport but remains on board the vessel without being discharged.

• If the Bill of Lading is issued directly to the shipper (no consolidation by a freight forwarder), it must be submitted 24 hours before loading at the last loading port before the UAE.
• If the Bill of Lading is for a consolidated shipment, it must be submitted 6 hours before loading at the last loading port before the UAE.

• If the House Bill of Lading includes the actual consignee and shipper, it must be submitted 24 hours before loading at the last loading port before the UAE.
• If the Bill of Lading consolidates multiple shipments (where the consignee is another freight forwarder), it must be submitted 6 hours before loading at the last loading port before the UAE.

The last loading port before the UAE is the final port where the cargo is physically loaded onto a vessel before its journey to the UAE. If a vessel stops at a port but the cargo remains on board without being unloaded and reloaded, that port does not count as a loading port for filing purposes.

• Example 1: A shipment is loaded in China and the vessel stops in Sri Lanka before heading to the UAE. Since the cargo was not unloaded and reloaded in Sri Lanka, the last loading port remains China, and filing should be submitted 24 hours before loading in China.
• Example 2: A shipment is loaded in China, unloaded in Sri Lanka, and then reloaded onto another vessel for the UAE. Since the cargo was physically reloaded in Sri Lanka, that becomes the last loading port, and filing should be submitted 24 hours before loading in Sri Lanka.

No, the deadlines apply only to the initial filing, which must be submitted within the required timeframe before loading. Updates can be made at any point during the shipment’s journey or even after arrival, as long as they are reasonable and aligned with operational practices.

Filers can submit filings through one of the following methods:

• Direct integration with NAIC (for shipping lines only).
• Through an accredited service provider (for all filers).

Yes, all filings must be submitted in EDIFACT CUSCAR 23A format to ensure standardization and compatibility with NAIC’s system. For filers using a certified service provider, the provider will manage all technical aspects of the submission, ensuring the correct format is applied.

You can submit through one of NAIC’s certified service providers. They will provide an interface where you can manually enter the required details or upload documents, and they will handle the conversion and submission of the data to NAIC in the required format.

If you are using a TMS, check if your TMS provider is one of NAIC’s certified service providers. If they are certified, your existing system should handle the filing seamlessly, without the need for additional data entry or separate filing. The service provider may enable a new functionality within your TMS to submit filings to NAIC automatically.

If a filer’s system is down, they must notify NAIC so that the filing can be temporarily waived until their system is restored. If NAIC’s system is down, filers will be notified, and filings will also be waived for the duration of the outage. All system downtimes will be monitored and reported by NAIC to prevent misuse or non-compliance.

Failure to comply with MPCI filing requirements—including late submissions, missing filings, or incorrect data—will be considered a violation and may result in fines.