Consultation Paper on Hong Kong Regulated Agent Regime
Carriage of Cargo By Air

Response by the Hong Kong Coalition of Service Industries
December 1997

1. We welcome the opportunity to comment on the above consultation paper. The following remarks are the result of consultation with selected members of the Coalition's Transport/Infrastructure Committee. As individual members of the HKCSI in specific sectors will have already responded from their specific points of view, the remarks in this paper are of a more general nature.
   
   
2. We fully support the "safety-first" principle and the adoption of the best possible security standards for Hong Kong's airport. The air services industry is critical to Hong Kong's competitiveness and the high standards of service must be matched by a fool-proof security regime.
   
   
3. At the same time, like the management of any operation, air cargo security should be run in the most efficient and effective manner possible. Hong Kong's air services industry is facing increasing competition from the region and services have become highly price-sensitive. For the same reason of competitiveness, the airport security system should be as cost effective as possible.
   
   
4. We welcome the view in the consultation paper that 100% screening of cargo by forwarders is not practical. Indeed that would be an overkill. We support the proposed regulated agent regime.
   
   
5. In commenting on the design for the regulatory regime we have had the benefit of the experience of the Hong Kong General Chamber of Commerce, a government-accredited regulatory agency for certificate of origin for exports of goods. The Chamber's example is that of an efficient and reliable regulatory system that makes full use of the private sector's expertise. Such regulatory advantages should be exploited to the full in designing the accreditation and certification system for the regulated agent regime.
   
   
6. To improve efficiency of the system we anticipate that there will be a role for ancillary services like security control audit services which could facilitate the checking process for freight forwarders and avoid congestion at the screening centre. As a means of fast-tracking the development of such ancillary service industries, government may like to consider if it should proactively enhance the growth of such services.
   
   
7. Express cargo: Express cargo has the character of being time sensitive, hence having a bigger demand on efficiency of the security regime. This will call for a more specific division of labour between the RAR, shippers and the air cargo operators to ensure that there is no double handling. It would appear that more detailed consultation among the parties involved would be required.
   
   

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If you have any question, free to email us at csi@hkcsi.org.hk