email@example.com Ho, ho, ho. The thought that Hong Kong may be compliant with the new maritime trade regulations for cargo manifests by the February 1 deadline is indeed a merry one. Try as we might, Hong Kong will not have put in place the massive systemic and cultural changes to adhere to the hastily conceived addendum of Washington's Container Security Initiative (CSI). The Bush administration's decision to ignore the advice of the global trade community and set a three-month deadline for adherence to the 24-hour electronic pre-submission of manifest rule has been described as taking the 'hard-landing approach' to the new initiative. Most of those consulated suggested a one-year grace period would be needed, if not longer. With six weeks left in the truncated grace period and news from Maersk Sealand that last week only 10 per cent of exports to the United States were listed adequately, it appears a 'crash landing' assessment would have been more apropos. It is becoming increasingly clear that US Customs Service officials could not have imagined the scope of the systemic and cultural changes Hong Kong, and Asia in general, would have to undertake to reach compliance. For example, it has been common practice for forwarders in cargo origin countries to request forwarders in Hong Kong to create 'dummy' manifests before submitting to the shipping line to disguise the original shipper. The majority of items in the shipment remain accurately listed, but the shipper's name and contact details are changed. The practice has been used to keep shipping lines from approaching the shipper direct, cutting out the forwarding middleman. One global forwarder estimated that 50 per cent of his company's business in Taiwan was conducted in such a manner, which of course is no longer acceptable to the US authorities. One US Customs official, in Hong Kong last week, was heard to ask: 'Are those practices common over here?' You mean US Customs didn't know what trade practices were common over here before deciding on the timetable for implementation of the new regulations? Now we know why they have been less than prompt in answering the hundreds of questions from anxious forwarders, carriers and shippers. It has been said that US Customs has no vested interest in providing too many forward-looking details as to how the CSI will work, not wanting to tip off those it is designed to deter on how to bypass the new anti-terror system. But an honest appraisal in Washington would undoubtedly question whether the Bush administration looked before asking others to leap. One has to wonder if they knew 95 per cent of Hong Kong's non-vessel owning common carriers could not even access the Automated Manifest Service, its designated portal, before setting the February 1 deadline. Below Deck pities the poor shipping lines that have been saddled with paying the penalties for our technically challenged forwarders and shippers. While they are putting a brave face on efforts to meet the deadline, we fear they don't really have much hope. Their already depleted bank accounts look set to shell out enough cash to fund Santa's precious Christmas Eve cargo run. Will Hong Kong's trade community be compliant with the new manifest regulations by February? Well, let's just say that Below Deck wishes that all your festive season events are filled with such humour. Merry Christmas.