ICES Advisory 38/2026: the six FAQs

On 21 September 2026 the Directorate General of Systems (DGoS, ICES) published ICES Advisory 38/2026, "Operational Advisory & Technical Clarifications: FAQs for Trade Stakeholders — Guidance on CSN, SAM, SAA Amendments, Flag Mapping, & Schema Validations". It is six questions and answers, and three of them settle things this knowledge base had until then marked as our own reading. This page takes the six in order: what you asked, what customs answered, what it changes if you are a forwarder or consolidator and if you are a shipping line, and what the app does about it.

Name it in full. ICES Advisory 38/2026 is not CBIC Circular 38/2026 — the 1 September 2026 rollout circular with the port-by-port dates, on Is SCMTR mandatory at my port yet?.

One thing holds for every answer below. The advisory is customs' published text, so what it states can be stated as customs' rule and cited to it. Customs' replies have since shown parts of it from either side — a drop and re-add accepted in one SAA (Q1), and a reference changed in place checked rather than refused (Q2) — but no acknowledgement on record yet shows any of it enforced as a refusal. So nothing here is a reason for a red mark in a check, and where this knowledge base measured the opposite before 21 September, that measurement is dated rather than deleted: customs says the system has changed, and it has not yet been seen from customs' side.

Q1: The line filed my master bill as a straight bill. How do my house bills get onto the manifest after the SAM?

Customs' answer depends on whether you, the forwarder, filed a CSN.

Scenario A — you filed a CSN. The line files an SAA in which it must "first drop (delete) the existing Straight BL line item and subsequently re-add the Master BL configured as consolidated, linking the reference details of the CSN and House BL provided by the forwarder".Scenario B — no CSN. The line must "directly incorporate the full underlying House BL details within the houseCargoDec object" of the SAA.

For a forwarder this closes a question this knowledge base could only reason about: the process CBIC's SCMTR team had set out for the trade said "delete SAM", and we read that as your bill's own line — because SACHM23 has no message that withdraws a manifest — while saying plainly it was our inference. It is now a published procedure for this case: what is dropped is "the existing Straight BL line item", inside the SAA. The phrase "delete SAM" is still the reported process's, not the advisory's, and reading Q1 as its meaning is still our inference — a well-founded one. Ask your line, in those words, to drop your line item and re-add it as consolidated against your CSN number and date. What the line needs from you, and what its amendment may carry, is on My console's house bills are not on the line's manifest.

For a line, Scenario A's re-added master "linking the reference details of the CSN and House BL" reads, with customs' own Trade Scenarios table, as a master line quoting the CSN with house rows that carry each house bill's reference, prior reference, customs location and containers — and not the transport document or item details the CSN already holds (370, with 118 on every house). Scenario B is the opposite: with no CSN, the house bills go in full. Neither shape has yet been seen accepted; the only shape seen to pass on record is a master line quoting the CSN with no house rows at all.

What the app does. On the line's side, Remove on the bill's row and Add a line from a CSN build exactly that drop and re-add, with a D on the old line number and an S on a new one — see Amending a shipping line filing. On the forwarder's side, Send CSN reference to the carrier produces the reference card with the CSN number and date the re-added line links to.

Q2: Can a line change a bill from straight to consolidated, or its consolidator PAN, in an update?

No. Changing a bill "from Straight to Consolidated (or vice-versa)", modifying the consolidator PAN, or altering the previous reference value (CSN / PCIN / MCIN) as an in-place update "is prohibited by system validation rules". The record "must be explicitly dropped (deleted) using the amendment deletion procedure and then re-filed in the SAA JSON structure with the correct cargo relationships".

For a line this is the general rule Q1 is a case of: any change to what a line is — its relationship to a CSN or a consolidator — is a deletion and an addition, never a correction. A request from a forwarder to "update our line to consolidated" is asking for what the advisory calls prohibited — though the one reply since (below) raised no code for such a change.

What the app does. Build amendment refuses an update that changes a line's consolidation indicator, consolidator PAN or prior reference, and tells you to remove the line and add it back. A removed line's number is not reused in the same editing session, so the amendment carries a D on the old line number and an S on a new one. Customs has accepted the D and the S in one SAA: a Kolkata amendment of 3 October 2026, after entry inward, removed a straight line whole — its containers and route legs marked D — and re-added the bill as a consolidation quoting the forwarder's CSN, and customs' reply accepted it with no code and issued the new line an MCIN. One acceptance, one shape; two earlier sends of the same change were refused for how the removed line was written (724, then 242/300).

What a reply has shown since. On 3 October 2026 customs answered a line's SAA, filed by the shipping line outside SCMTR, that changed a line's prior reference in place — an update re-pointing it at a forwarder's house PCIN. The reply raised no code for the change itself; the codes it did raise are the ones a comparison with that CSN would give — the consolidator PAN (360 — a line quoting a CIN names the CSN's filer) and the container size (398) — beside its totals (89/90). Re-sent the same day with the totals, the size and the forwarder's PAN put right, the line was refused again: 360 with 150 ("PAN Not Authorised To Submit Declaration"). So no code names the change in place as such, but a line re-pointed at a house PCIN of a CSN on another master bill has been refused twice, whatever PAN it named — the reference itself is what customs will not take. No such update has yet been seen accepted; the drop-and-re-add has (Q1 above). The app's note on an opened SAA says both.

Q3: Which flags does an SAA carry — msgTyp and amdType?

Customs' table, from the SACHM23 guide:

For everyone: msgTyp has two values on the wire, F and A. D is in the MIG's code list for msgTyp but never on the wire — the advisory's table lists only F and A — and a deletion is A on the header with D on the record, which is what this knowledge base already said of the CSN. U is for allowable fields — Q2 names three that are not. The flags and where each goes are on Amending a shipping line filing and Coded values.

Q4: Is my container ISO code or container agent PAN still checked on the CSN?

No — only on the SAM now. Both used to be validated twice, at the CSN and at the SAM. Because container inventory and agency "fall primarily under the operational custody and responsibility" of the line, checking them on forwarders "resulted in frequent validation failures and inadvertent rejection", and the two validations "have been de-linked from the CSN level and are now validated solely at the SAM (Vessel Operator/Line) level".

For a forwarder, the container size code and the container agent PAN still matter — the line's manifest is checked against them and your box should read the same as the line's — but a refusal over them, if any, is on customs' account now the line's, not yours — which error codes that covers, the advisory does not say. For a line, customs says the check is yours alone.

What the app does. Nothing changes in what is asked for: the size code is still read off the box, the agent PAN still follows the bond, as Coded values and Party codes and PANs describe. The refusals and acceptances those pages count were measured before the advisory. One refusal since fits it: on 3 October 2026 a line's SAA was refused 398 "Eqmt Size Not Match With Referred Eqmt Size of CIN" — the line's container size against the forwarder's CSN it quoted. The CSN's size matched both bills of lading (a 40 ft open top, 4250) and the line's manifest did not (4210, 40 ft dry): the refusal fell on the line, as the advisory says, and the fix was the line's — but a forwarder who changes a right code to match the line's wrong one moves the mismatch onto their own CSN. Keep the code the box shows.

Q5: Can I delete a CSN I filed wrongly, before the line's SAM, and file it again?

Yes. "An option for cancellation/deletion of a CSN by the ANC has been enabled on the customs system, provided that the corresponding SAM has not yet been filed against that CSN. Once deleted, the ANC can promptly re-file corrected particulars without generating mismatch conflicts."

For a forwarder, this is the relief you asked for, with its condition: once a SAM references your CSN, the deletion is no longer yours (ICES Advisory 37/2026 has it go through the jurisdictional officer). Before that, delete and re-file.

What the app does. File a deletion is already offered on an accepted CSN until the line's manifest covers the bill, and withdrawn after. What is dated is the warning beside it: this knowledge base measured, in September 2026 and before the advisory, a fresh filing on the same bills refused as a duplicate (122/123) after an accepted deletion — see Deleting does not free the bill of lading. Customs now says a re-file after a deletion goes through "without generating mismatch conflicts". No acceptance on record yet shows it; if yours does, the warning is what changes next.

Q6: Why is my acknowledgement for a large manifest so late, and what has changed?

Three things, customs says: dedicated background schedulers "to isolate and ingest large-size JSON manifests without choking general traffic"; database indexing "for faster record retrieval and validation turnaround"; and a Submission Status Enquiry Utility "under implementation", to track the processing status of a submitted manifest file.

For a line, the first two are already in place, by customs' account, and the third is announced and not live. Nothing in the advisory gives a target time.

What the app does. The same as before, because the utility does not exist yet: an acceptance of a fresh CSN is read off customs' own record about every fifteen minutes (After you file), a rejection still arrives only in the emailed acknowledgement and is read when you drop it on the filing, and a manifest's reply is read the same way (Working with a shipping line filing). When the enquiry utility is published, this page will say what it shows.

What did the advisory not settle?

Whether the drop and the re-add go in one SAA or two. "First drop… and subsequently re-add" reads as one amendment; the advisory does not say so. Customs has since accepted one SAA carrying both (October 2026); whether two separate ones are also taken has not been seen.The codes on the re-added master and its house rows. "Configured as consolidated, linking the reference details of the CSN" reads as consolidation indicator C with a prior reference to the CSN; the advisory names no codes and says nothing about the house rows' own flags.Anything after Sea Entry Inwards. The advisory does not mention entry inward, so the disagreement between the manifest guide's 373/374 and ICES Advisory 37/2026's officer approval stands — see How late can an arrival manifest be amended?.The three windows, and the berthing boundary between them. Those come from the process CBIC's SCMTR team set out for the trade, not from any advisory, and this one does not add them.

Related

My console's house bills are not on the line's manifest — the forwarder's side of Q1 and Q2Amending a shipping line filing (SAA or SDA) — the line's side, step by stepSCMTR rollout, amendment windows and penalties — every dated rule, including ICES Advisory 37/2026'sChanging or withdrawing a filing customs already accepted — the CSN side of Q5Chennai customs' SCMTR help desk — a Commissioner's letter of 24 September 2026 that describes the Q1 step as "CSN deletion", and where a refused SAA/SCA's Unique ID goes at Chennai

This page is informational. It quotes ICES Advisory 38/2026 and says where the app follows it; it is not legal or customs advice, and practice varies by port and by line. Confirm anything that matters with your jurisdictional customs officer, your shipping line, or ICEGATE before you act on it.