Two companies, one master bill of lading

This is the single most expensive thing to learn late under SCMTR, and almost nothing tells you about it until it has already happened.

Both of you file. That is the design, not a clash

A consolidated shipment produces two separate cargo declarations against the same master bill of lading:

You, the freight forwarder, console agent or NVOCC, declare the house cargo — the individual shippers and consignees whose goods you combined into that container.The shipping line declares the master — the bill they issued, at the vessel level.

The line has two ways of doing that, and both are allowed. It can file its own CSN against the master bill, or it can declare the master directly in its arrival manifest (the SAM), the vessel-level message only the carrier or its agent may file. ICEGATE's SCMTR FAQ says the carrier may declare all the cargo in a single manifest, or build the manifest by aggregating the CSNs other parties filed. Which route your line takes is its choice, not yours.

Customs then cross-validates the two against each other. Neither of you is filing "instead of" the other, and the line filing against your master B/L does not invalidate anything you sent.

So the first thing to be clear about: the shipping line filing is normal and expected. It is not a conflict with your declaration.

Two things the official documents say about how the pair is meant to fit together:

Your CSN is optional in law. ICEGATE's FAQ calls it "a facilitative measure": a way for the party that actually holds the cargo details to declare them to customs directly, without handing them to the line. A forwarder is free not to file one and to give the details to the line for its manifest instead. Filing it is what keeps your shippers' and consignees' details in your hands.The line is meant to refer to your CSN, not re-declare the bill. The same FAQ says that once cargo-level details have been furnished for a bill by the forwarder, the consolidator or vessel operator will not be able to give details for that bill again — the manifest refers to the CIN customs issued to your filing, through the master consignment's previous declaration block. CBIC's clarifications add that the line can see every CSN filed against its vessel inside its own ICEGATE login, so it does not need your file to do so.

Is there a deadline for the CSN itself?

There is one, and it is not a clock in hours. CBIC's own table of what is filed under SCMTR and by whom puts the CSN — SCE, SCX, SCD and SCA alike — at "before departure from the last port of call": before the vessel leaves the last foreign port on its way to India, which is the same point the table sets for the carrier's own arrival manifest.

Nothing published turns that into a number of hours before arrival. If somebody has handed you a table of hours, check whose it is: the 6, 24 and 48-hour windows that circulate are the carrier's, and they are about whether an amendment to its manifest needs an officer's approval, not about when a CSN is due.

Two things sit either side of that.

A CSN is optional in law, as the section above says — ICEGATE's FAQ calls it a facilitative measure, and a forwarder is free not to file one and to hand the details to the line instead. That does not put it outside the regulations: Regulation 13 provides a penalty of up to ₹50,000 for contravening any provision of them, and nothing published carves a CSN out of that.

In practice the line's filing is the real deadline, and it lands well before the ship sails from the last port of call. Measured on ten real master bills carrying both filings, the line's came in on or after the forwarder's CSN every time — nine of the ten strictly after, by a median of two and a half days — and landed one to three days before the vessel was granted entry inwards. So "how late can I be" answers as before the line files: days before arrival, not hours, and on a date nobody will tell you.

That also settles the trade against waiting for a VCN. Waiting costs you nothing while the line has not filed and everything the moment it does, so file as soon as you hold the real number, and never hold a finished filing back for anything else.

The same point decides who pays for a mismatch. Before the line files, a correction on either side is free; after, it is the line's IGM amendment (SAA), which lines charge up to ₹10,000 a request for, with the Bill of Entry waiting on it. SCMTR checks your CSN against the line's SAM at Sign & upload, and a line can share its SAM before filing so every CSN holder is told — see Check your CSN against the line's SAM.

What does their filing close on my side?

Here is the part that catches people — and since ICES Advisory 37/2026 (18 September 2026) the answer depends on which of their filings it is, and on what you want to do.

Another party's CSN closes the most. Once another filer's CSN for that master bill of lading is accepted — the line's own CSN, or another forwarder's — your CSN is linked to it, and customs' own error list names what it may refuse from your side from then on:

Those three are read off ICEGATE's published validation table; they are what the rule looks like on the wire. It is wider than corrections: a brand-new CSN against that master is refused as well. 320 itself has not been seen on a reply, here or in a filer's hands, so an amendment or deletion after another party's CSN is a risk rather than a certain refusal: amend before theirs lands if you can, and if 320 does come back, settle it with the shipping line and your jurisdictional customs officer. Since 29 September 2026 the app warns of 320 rather than stopping the amendment, because no refusal carrying it has been seen.

The line's manifest (SAM) closes less. By the advisory:

An amendment is still yours to file. File it (SCA), then give the line the amended CSN and MCIN/PCIN so it can file a matching manifest amendment (SAA). Once Sea Entry Inwards is granted, both need the jurisdictional customs officer's approval.A deletion is the officer's. After the SAM, the jurisdictional customs officer carries it out; you do not file it.A fresh CSN is not the route. The advisory has the CSN filed before the SAM, and has the line add any house bills its manifest is missing by amending the manifest (SAA, "splitting of BLs").

Until 19 September 2026 this page treated the manifest exactly like another party's CSN — 320 on any amendment. That was an inference no ICEGATE refusal ever confirmed; the advisory is customs' published process, and it says otherwise. No filing on record here has yet been seen amended after a manifest either, so the list above is what the advisory says, not something observed.

But 122/123 do not only mean this. The same pair is returned when your own earlier filing still holds the bill — and once, before ICES Advisory 38/2026, it was returned on a bill whose CSN the filer had deleted, as if the deletion had closed the record without releasing the bill number. The advisory (21 September 2026) says a CSN deleted before the SAM can be re-filed without a mismatch; whether that has reached the live system has not yet been seen either way. Before concluding the line has filed, check customs' accepted-filings record; before concluding it has not, read Deleting does not free the bill of lading.

The platform now asks both questions as you type the bill number, on the guided steps and in the full form alike. It checks your own organisation's live filings for that master or house bill, and asks customs' own record whether the master is still open to you. It warns and never blocks — you and the shipping line file separate CSNs against the same master on purpose, so anything that stopped you would be wrong, and a filing shown as submitted may have been refused an hour ago, which makes re-filing exactly right. It says nothing at all when there is nothing to say, which is the ordinary case.

"Another filer has already sent a CSN on this bill" is a third notice, beside the bill number and again at Sign & upload, and it means exactly that: another organisation using SCMTR has sent a CSN on the same master B/L at the same port of reporting — awaiting customs' answer, or already accepted. It tells you how many and whether customs has accepted theirs, never who; customs' own public record names the filer, and the notice links to it. Nothing anyone is still drafting is counted. It is not a stop — it is usually the shipping line or the console agent on the other side of your consolidation, and that is expected — but it is the moment to check what customs already holds on the bill before you send, because the two filings are compared on the bill date, the package count and each container, and where they disagree the later one is refused. Sign & upload pauses once on it and goes on when you say so.

There is no notice and no grace period, because the deadline is not a date — it is somebody else's action, and it can happen at any moment. That is what makes it different from every other deadline in the regulation.

What that means in practice

Amend the day you notice something wrong, not the week after. Waiting is a real risk rather than a theoretical one. There is no queue you can join and no extension to ask for.

A vessel substituted after customs accepted your CSN is not something an amendment fixes. The carrier's revised arrival notice names a different ship, and with it a different VCN; your accepted filing still carries the old pair. ICES Advisory 37/2026 says anything in a CSN can be amended except the VCN and rotation number, so raise it with the shipping line and your jurisdictional customs officer the day you notice, while the most routes are still open. The app's check of the VCN against customs' list of the ship's calls runs while you prepare, before you file, and on the filing's page while it can still be amended — the last of those against customs' latest answer as the platform already holds it, with Check now to ask again — so a substitution notified once the CSN is accepted is caught there as well as from the arrival notice; see I prepared the filing early for what the check covers and The ship changed after customs accepted my CSN for what is and is not known about the fix.

Once another party's CSN is accepted, an amendment may be refused (320, not yet seen on a reply). If it is, the declaration has to be settled with the shipping line and your jurisdictional customs officer.

How to see it coming

The event that may close your window is the other party's CSN being accepted — and since September 2026 that is directly visible, days before the manifest exists: customs' public record of accepted filings lists every CSN against a master bill from the moment it is accepted (see What customs already holds).

Only your filing on the record — the other party has not filed yet. Your window is open.Another filer's CSN on the record — customs accepted it; a fresh CSN is refused, and an amendment or deletion risks 320.

The same public record shows the line's manifest against your master bill, under the reporting event SAM, from the moment customs accepts it — so a line that files the manifest directly rather than a CSN is visible there too. Measured across real shipments, the manifest lands up to five days after the forwarder's CSN and one to three days before the vessel is granted entry inward. The older Sea Arrival Manifest enquiry still works but answers later, because the IGM only exists once the vessel is near the port. The manifest does not shut your window to an amendment (see above), but from the moment it is accepted a deletion is the officer's and a fresh CSN is not the route.

The app reads the accepted-filings record for you on every filing — the other parties' CSNs and the line's manifest, since a line may file the manifest and never a CSN — and shows the result on the declaration page, naming whose filing it is, when it was accepted, and what it still leaves you. It also checks at every point where you might act on a master B/L: while you type the bill number in the wizard, on an imported JSON file before you build a draft on it, and at submission — where a filing customs would refuse is stopped rather than sent (a fresh CSN on a bill another party's CSN holds — an amendment or deletion there is warned of, not stopped; a fresh CSN or a deletion, but not an amendment, on a bill the line's manifest covers). And it watches in the background after you file: if the other party's accepted filing disagrees with yours on the fields customs compares, you are emailed about it while the window is still open — the one moment the disagreement is cheap to fix.

Note the same fact means two opposite things depending on what you still need to do. If you have already filed and been accepted, finding the manifest is good news: your bill reached it. If you still need to file fresh or delete, finding it means those are no longer yours to do; an amendment still is, with the line's SAA to follow it.

What customs actually compares between the two filings

The cross-check is narrower than people expect. Error codes 232–238 name seven physical facts about the container, 164 adds the master bill's date, and nothing else is published:

the total number of packagesthe total number of equipment (containers)and per container: its type, ID, size, load status and SOC flag

Everything a filer would regard as commercially sensitive — your shippers, your consignees, your rates — is outside that list entirely. The two declarations are compared on what is physically true about the steel box, not on your commercial relationships.

This is why a disagreement usually comes down to something small and mechanical: a container type written 2200 on one filing and 2210 on the other, or a package count that was rounded on one side.

Two refinements, both from filings customs has refused or accepted. The bill of lading date is compared as well as its number (164), and a load status unlike the one on the CIN the line quotes has been refused (399). And customs compares the line with your CSN only when the line quotes it: a line carrying the bill with its own house bills, or under its own MCIN, is not compared with your CSN at all, and on such lines a shared box is routinely FCL on the line and LCL on your CSN.

Can I compare my filing against the line's manifest, field by field?

Asked by a filer on 2026-09-08, in these words: "first we get the details of the ANC filing and after that the shipping line files the SAM — there should be a compare tool to match the values."

The comparison already runs; what does not exist is a screen you drive yourself. Three things do it, in the places the answer matters:

Automatically, after you file. The platform keeps reading customs' record of accepted filings against your master bill, and when the other party's accepted filing disagrees with yours on a field that must match, it emails the person who created the filing with the exact differences — while the amendment window is still open. The subject says which kind: "Action needed" for a difference customs has refused filings for, "Check:" for one that should match but has not been seen refusing. A difference customs allows is never e-mailed, and each other filer's filing is e-mailed about once, not on every reading. You do not have to go and look.Before you file, against what customs already holds. The customs lookup reads every accepted CSN against a master bill, the carrier's arrival manifest once it exists, and the vessel's entry status, and shows them as one shipment: facts the filings agree on stated once, a fact only one source carries attributed to it, and a genuine disagreement between filers flagged.On the manifest itself. Open a line's SACHM23 file — or one already kept here, with no upload — and its bills can be checked against the CSNs filed for them, line by line, each CSN shown as the same scorecard with a message to the forwarder ready to copy.

And the side-by-side exists now. Once the line's manifest (or another CSN) is on your master bill, your CSN's page shows every field the two can be compared on, both values beside each other, in three groups — Fix (customs has refused filings where these differ), Check (should match) and OK to differ — with one line at the top saying which applies. What must match between the line's manifest and the forwarder's CSN lists every field and how the groups were worked out.

If your filing is rejected on one of those fields

Whoever files second is the one who gets the rejection, because customs has the first filing to compare against. That does not mean the second filer is the one who is wrong.

Check the differing fields against the physical container and your bill of lading before changing anything. If your values are right and theirs are not, the correction belongs on their side — and if customs has refused your amendment with 320 because another party's CSN is on the bill, that is a conversation with the line and your officer rather than something either portal can fix.

The line filed the manifest "as per the MBL" and ignored my CSN

A consolidator's version of this: the CSN is accepted, and the line then files its arrival manifest straight from the master bill, as if no CSN existed. The question that follows is whether customs should have refused that manifest.

On paper, the rule exists. ICEGATE's FAQ says the operator cannot give details for a bill the forwarder has already declared, and the validation table carries the codes for it — 122 "MC-MBL Details Already Exists" and 171 "Previous Declaration is Not Mentioned in MC-Ref". CBIC's clarifications say that when the CSN came first, the MCIN was generated then and the manifest should simply refer to it.

In practice, nobody outside customs can promise you the manifest gets an error. No manifest rejected on this ground has been seen, and a line reporting that its manifest went through is evidence that either the check is not enforced on that path or the two filings never matched. Rule the second out first: customs matches your CSN to the manifest on the master B/L number exactly as written, the B/L date and the port of reporting. A prefix the line adds or drops, a different date, or a different reporting port makes the two filings unrelated as far as customs is concerned, and then neither side sees any error at all.

What to check, per shipment. Look the master bill up on customs' accepted-filings record — the tracking page does this for you, or ICEGATE's New SAM/IGM enquiry directly — once under your CSN and once under the line's manifest, same port and B/L date. Then read the house lines:

Your house bills carry an IGM line and sub-line. They are on the IGM, and the importer's Bill of Entry can be filed against them. Nothing more is needed, however the line filed.The manifest is there and your house lines carry no IGM line. The manifest did not carry them. The remedy is the line's: an amendment to its manifest (SAA) referring to your CSN's MCIN or PCIN. That, with the master bill, port, your CSN number and CIN and the rotation number, is what to put to the line and, if it will not act, to the jurisdictional SCMTR nodal officer.

Meanwhile, do not wait to correct your own filing. Another party's CSN against your master bill may lock yours to amendment (320 above, not yet seen on a reply) whenever it lands. The line's manifest does not — since ICES Advisory 37/2026 (18 September 2026) you still file the amendment and give the line the amended CSN and MCIN/PCIN for its SAA, and after Sea Entry Inwards both wait on the officer's approval. So correct a CSN before the manifest lands where you can; after it, one correction takes two filings. (Until 19 September 2026 this said the manifest locked your CSN too. That was an inference no refusal confirmed.) The app's watch reads the manifest as well, and the filing's page says what it still allows.

See Tracking your cargo for reading the two enquiries, and Bill of Entry and the IGM for what an empty IGM line means for the broker filing against your house bill.

Related

Amendments, deletions and the states closed to them: Amendments and deletionsWhat each rejection code means: Rejection reasons and Error codesWhich reference number is minted by whom: Every reference number, who issues it, and when