Type 1 Ocean Cargo Transport Business Registration

This page is a translation for reading support. The Japanese article is the official version. For legal, customs, insurance, or regulatory decisions, please confirm against the Japanese original and the relevant parties.

Type 1 Ocean Cargo Transport Business Registration

Type 1 Ocean Cargo Transport Business Registration is the procedure by which a business obtains registration from the Minister of Land, Infrastructure, Transport and Tourism in order to undertake international ocean freight forwarding from Japan to a foreign country by using transportation performed by a vessel operator or another freight forwarding business operator.

In practice, it principally applies to a Port-to-Port NVOCC operation in which the business undertakes carriage from a loading port in Japan to a destination port overseas and issues a House B/L, Sea Waybill or other transport document in its own name.

The registration requirement is not determined solely by whether a document is called a House B/L. The actual business must be reviewed to determine whether the operator responds to the demand of another person for consideration and undertakes ocean freight forwarding in its own contractual capacity.

Type 1 ocean registration does not by itself authorize the business to undertake every domestic pickup, overseas delivery, air carriage, customs-clearance, port-transportation, warehousing or insurance operation under its own transportation responsibility. Other registrations, permissions and contracts must be reviewed according to the stage undertaken for the shipper.

For international freight forwarding, the Consigned Freight Forwarding Business Act applies to export freight forwarding from Japan. Import and third-country international freight forwarding are outside that international regulatory scope. However, domestic freight forwarding performed after cargo is discharged in Japan may separately fall within the Act.

Purpose and Background of the Registration System

A consigned freight forwarding business uses transportation capacity supplied by a vessel operator, airline, railway operator or motor carrier while undertaking transportation for the shipper without operating the relevant vessel, aircraft, railway or truck itself.

A mere intermediary principally facilitates a transportation contract between the shipper and the actual carrier. A consigned freight forwarding business operator, by contrast, enters into the transportation contract in its own capacity, collects freight from the shipper and subcontracts the physical transportation to another operator.

The Type 1 ocean registration system examines the business plan, contractual relationships, facilities, financial basis, general conditions of carriage and disqualification grounds of the applicant in order to protect users and ensure proper operation of the business.

The registration is therefore not merely an authorization to print House B/L forms. The operator must organize the stage undertaken as carrier, the Actual Carrier used, the applicable terms, the freight structure and the response to cargo claims.

Scope of This Article

Issue Covered in This Article Article or System Providing Further Detail
Type 1 ocean registration New registration of a Japanese operator conducting export ocean freight forwarding This article
Port-to-Port transportation Carriage from a loading port in Japan to an overseas destination port NVOCC and House B/L articles
Transportation with collection or delivery on only one side Combination of Type 1 ocean registration with another Type 1 registration Type 1 Motor Truck Freight Forwarding Business
Door-to-Door transportation Distinction from integrated carriage including collection and delivery on both sides Type 2 Ocean Freight Forwarding Business
Sea & Air Review of the contractual and registration scope of the ocean and air stages Type 1 and Type 2 International Air Freight Forwarding Business
Foreign nationals and foreign-controlled entities Distinction between the Japanese-operator procedure and the separate foreign-operator procedure International Freight Forwarding Business by Foreign Nationals
Import and third-country transportation Explanation that such international forwarding is outside the international scope of the Act Domestic transportation after import must be reviewed separately
Post-registration operation Terms, tariffs, display, changes, reports and internal controls General conditions and business-reporting articles

Situations in Which Type 1 Ocean Registration Is Relevant

Business Situation Stage Undertaken for the Shipper Position of Type 1 Ocean Registration Additional Review
Ocean carriage from a Japanese port to an overseas port Port-to-Port international ocean stage Typical Type 1 ocean operation Terms, Actual Carrier contract and House B/L
LCL transportation from a Japanese CFS to an overseas CFS CFS-to-CFS ocean transportation Central Type 1 ocean operation Whether CFS handling is ancillary or separately contracted
FCL transportation from a Japanese CY to an overseas CY CY-to-CY ocean transportation Typical Type 1 ocean operation Container handover points and period of responsibility
Transportation from a domestic factory to an overseas port Domestic truck stage and ocean stage Type 1 ocean applies to the ocean stage Type 1 motor-truck freight forwarding registration
Transportation from a Japanese port to an overseas inland destination Ocean transportation and overseas delivery Not necessarily Type 2 where only one side includes collection or delivery Foreign law, agency contract, document and period of responsibility
Transportation from a domestic factory to an overseas inland destination Domestic collection, ocean transportation and overseas delivery under one contract Likely to require Type 2 review Collection and delivery plan, overseas agent agreement and Type 2 permission
Ocean transportation followed by air transportation Ocean stage alone or combined ocean and air stages Type 1 ocean applies to the ocean stage International air registration if the air stage is also undertaken

Difference among Type 1, Type 2 and Other Freight Forwarding Registrations

Business Form Typical Period of Responsibility Basic Registration or Permission Central Test Operational Caution
Type 1 Ocean Freight Forwarding Business Loading port in Japan to overseas destination port Type 1 ocean registration Whether the operator undertakes the ocean stage in its own capacity Match the Port-to-Port document with the actual responsibility
Type 1 Ocean plus Type 1 Motor Truck Domestic factory to Japanese port and then overseas port Separate Type 1 registrations for ocean and motor-truck stages Whether collection or delivery exists on only one side One-sided collection does not constitute Type 2
Type 2 Ocean Freight Forwarding Business Domestic collection, ocean trunk carriage and overseas delivery under one arrangement Type 2 ocean permission Whether both preceding collection and subsequent delivery are integrated with the trunk stage A collection and delivery business plan is required
Type 1 International Air Freight Forwarding Business Japanese airport to overseas airport Type 1 international air registration Whether the operator undertakes the air stage Sea & Air requires separate review of each mode
Mere transportation intermediary Facilitation of a contract between shipper and carrier Registration may not be required Whether the intermediary becomes the transportation contracting party Quotation, billing, B/L name and liability statements must be consistent
Customs, warehousing and insurance services Clearance, storage, packing or insurance arrangement Separate laws and qualifications apply Whether the activity is ancillary or separately regulated Do not treat Type 1 ocean registration as authority for every service

Type 2 business integrates trunk carriage by vessel, aircraft or railway with both the collection preceding that trunk carriage and the delivery following it.

Transportation from a domestic factory to an overseas port, where collection exists only on the Japanese side, is therefore generally structured through separate Type 1 motor-truck and Type 1 ocean registrations rather than Type 2 permission.

The result is determined by the actual contractual responsibility, not by whether the service is commercially described as Door to Door.

Situations Outside Type 1 Ocean Registration or Requiring Additional Authority

Situation Why Type 1 Ocean Alone Is Insufficient Additional System or Contract to Review
Domestic pickup undertaken under the operator’s responsibility The domestic motor-truck stage is not ocean carriage Type 1 Motor Truck Freight Forwarding Business
Integrated collection and delivery on both sides of the trunk stage The operation may meet the Type 2 definition Type 2 Ocean Freight Forwarding Business
Air carriage undertaken under the operator’s responsibility Air transportation is a separate transportation mode Type 1 or Type 2 International Air Freight Forwarding Business
Customs declarations filed for customers Customs brokerage is separately regulated Customs-broker permission or subcontracting
Port transportation undertaken directly Port transportation is a separate regulated activity Port Transportation Business Act
Independent warehousing business Commercial warehousing may require separate registration Warehousing Business Act
Solicitation or conclusion of cargo insurance Insurance solicitation is not included in the forwarding registration Insurance-business qualifications and agency agreement
Application by a foreign national or foreign-controlled entity A separate international forwarding procedure applies International Freight Forwarding Business by Foreign Nationals
Import or third-country international forwarding only Such international forwarding is outside the international scope of the Act Domestic post-import stage, foreign law and contractual responsibility

Principal Operations under Type 1 Ocean Registration

  • Entering into an ocean transportation contract with the shipper.
  • Using transportation performed by a shipping line or another ocean freight forwarding business operator.
  • Issuing a House B/L, Sea Waybill or other transport document in the operator’s own name.
  • Collecting freight and charges from the shipper.
  • Paying freight to the Actual Carrier or other freight forwarding business operator.
  • Responding to the shipper regarding transportation performance, cargo casualties and claims under the operator’s own contract.
  • Performing documentation, storage, packing, collection of charges and other work normally ancillary to ocean freight forwarding.

Where physical cargo damage is caused by a shipping line, CFS, port operator or overseas agent, the NVOCC must still consider its initial contractual response to the shipper.

Recourse against the physical wrongdoer and responsibility to the shipper are separate issues.

Principal Registration Requirements

Requirement Matter to Confirm Principal Record Operational Caution
Classification of the business The proposed operation qualifies as Type 1 ocean freight forwarding Service design, quotation, contract and draft transport document Review Type 2 and other modes before applying
Basic asset amount The basic asset amount is at least JPY 3 million Most recent balance sheet Deferred assets and goodwill are excluded from the calculation
Disqualification grounds The applicant and officers do not fall under statutory refusal grounds Declarations, officer list and curricula vitae Review every officer, not only the corporation
Office The applicant has an office necessary for the business Lease, registry records and declaration of right of use Match the registered office with the actual operating location
Storage facility Necessary capacity and theft-prevention measures exist where storage is required Facility description, area, structure and equipment Explain the subcontracting structure if no facility is owned
Actual Carrier contract A transportation relationship exists with a shipping line or forwarding operator Transportation agreement or freight quotation Show a reasonable contract for ocean transportation
Business plan Mode, area, offices, business scope, facilities and operators used are specified Business plan Describe the actual commencement plan rather than a future aspiration
General conditions The standard ocean conditions or approved independent conditions will be used Conditions and approval application An English independent form may require a certified Japanese translation
Japanese or foreign-operator classification The applicant is eligible for the Japanese-operator procedure Representative, officers, voting rights and incorporation records A Japanese corporation may fall within the foreign-operator definition

Basic Asset Amount of at Least JPY 3 Million

The financial requirement is not determined solely by the net-assets line shown on the accounting balance sheet. It is based on the basic asset amount calculated under the applicable regulations.

The calculation generally starts with assets recorded on the balance sheet or statement of property, excludes organization expenses and other deferred assets and goodwill, and deducts liabilities.

Item Treatment Caution
Total assets Assets on the basic asset statement form the starting point Use a different value where an actual valuation difference is clear
Deferred assets Organization expenses and other deferred assets are excluded Accounting net assets may differ from the statutory amount
Goodwill Excluded from the asset calculation Important where substantial goodwill arose through acquisition
Liabilities Deducted in full Review material changes after the most recent financial statements
Capital increase A clear post-balance-sheet increase may be considered Prepare objective evidence of payment and increase

Principal Application Documents

Document Principal Content Preparation Caution Applicable Applicant
Type 1 Freight Forwarding Business Registration Application Applicant, representative and transportation mode State international ocean transportation as the mode All applicants
Business plan Area, offices, scope, facilities and operators used Match the actual service and responsibility All applicants
Transportation agreement Relationship with a shipping line or forwarding operator A qualifying freight quotation may sometimes support the relationship All applicants
Office documents Compliance with relevant laws and right to use Check location, lease name and actual use All applicants
Storage-facility details Area, structure, equipment and security measures Explain the subcontracting structure where no facility is owned Where storage facilities exist
Articles of incorporation Corporate purpose and organization Include freight forwarding within the corporate purpose Corporations
Certificate of registered matters Corporation, representative, office and purposes Use current registration information Corporations
Balance sheet Review of the basic asset amount Use the most recent business year Existing corporations
Officer list and curricula vitae Names, addresses and career history Include every relevant officer Japanese corporations
Declarations regarding disqualification Confirmation that no statutory refusal ground applies Normally required for all officers Corporations and other applicants
General conditions Receipt, delivery, charges and liability State use of the standard conditions in the business plan Approval application where independent conditions are used

Application Desk, Submission and Standard Processing Period

The application is addressed to the Minister of Land, Infrastructure, Transport and Tourism and submitted to the office responsible for international ocean freight forwarding. Submission may be made through the relevant ministry office, regional transport bureau, Kobe District Transport Bureau or Okinawa General Bureau as applicable.

Current ministry guidance also describes submission by mail. The applicant should confirm the addressee, traceable delivery method and requirements for return of a stamped copy.

The standard processing period for Type 1 registration is normally two to three months from arrival of the application at the designated office. Preparation, prior consultation and the period required for corrections are separate.

Process from Business Design to Commencement

Stage Action Decision Common Hold
1. Business design Define the stage, document, freight and responsibility Type 1, Type 2 or another mode Commercial description does not match the proposed registration
2. Prior consultation Discuss the proposed business plan with the competent office Application category and required documents Responsibility in multimodal carriage is unclear
3. Financial review Calculate the basic asset amount At least JPY 3 million Exclusion of deferred assets and goodwill causes a deficiency
4. Carrier relationship Prepare the shipping line or forwarding agreement Whether transportation can be performed continuously Contracting entity differs from applicant
5. Facility review Organize offices and storage arrangements Right of use and necessary capacity Lease or address does not match
6. Conditions selection Select standard or independent general conditions Whether approval is required House B/L terms conflict with the selected conditions
7. Application preparation Prepare the application, plan and attachments Consistency of all documents Missing area, office or Actual Carrier information
8. Submission and correction Submit and respond to enquiries Compliance and feasibility Insufficient supporting records
9. Registration Receive the registration notice and number Consistency with the approved plan Business must not begin before registration
10. Operational preparation Implement the House B/L, conditions, quotations and claims procedures Operation within the registration scope Sales personnel offer unrestricted Door-to-Door service
11. Post-registration duties Handle tax, tariffs, display, reports and changes Deadlines and competent office Registration is incorrectly treated as completion of all procedures

General Conditions and House B/L

A Type 1 operator must establish general conditions of carriage and generally obtain approval. Where the operator uses conditions identical to the standard ocean freight forwarding conditions established by the Minister, individual approval is deemed to have been granted.

Independent conditions must not harm the legitimate interests of the shipper and must clearly address receipt and delivery of cargo, collection of charges and the responsibility of the operator.

The approved or standard conditions, House B/L reverse terms, quotation conditions and claims procedures should not conflict.

Port-to-Port Transport Documents

Field Example Meaning Caution
Place of Receipt Yokohama CY Contractual place at which the NVOCC receives the cargo A domestic factory requires review of the domestic transportation stage
Port of Loading Yokohama, Japan Ocean loading port Must match the actual loading port
Port of Discharge Singapore Ocean discharge port Do not casually state an airport as a discharge port on an ocean B/L
Place of Delivery Singapore CY Contractual place of delivery An inland destination requires review of responsibility and authority

The existence of Place of Receipt and Place of Delivery fields does not permit unrestricted use of domestic factories or overseas inland destinations. Where the operator assumes responsibility to that location, the necessary registration, contract, conditions and insurance must support it.

Sea & Air Transportation

Contract Form Operator’s Responsibility Registration Review Document Caution
Ocean stage only Japanese port to overseas transshipment port Type 1 ocean is central Clearly identify the end of the ocean stage
Air stage contracted directly by the shipper Operator undertakes only the ocean stage Air registration may not be required for that operator Do not represent that one through carriage has been undertaken
Ocean and air stages under one contract Japan to final airport or destination Review both ocean and international air registration Use appropriate multimodal terms and responsibility rules
Integrated collection and delivery on both sides Pickup through final delivery Review Type 2 and multimodal permissions Prepare the collection and delivery plan and agency structure

Post-Registration Duties and Operational Controls

Item Principal Requirement Timing or Caution
Registration and license tax Payment of JPY 90,000 for a new registration Within one month after the registration date
Fares and charges report Report established or changed fares and charges Confirm the current form and competent office
Display of business information Display business type, mode, conditions and area At the principal office and other business offices
Business overview report Report business and financial information Within 100 days after each business year
Business performance report Report annual cargo-handling results By July 10 each year
Registration of changes and notifications Changes to mode, area, office, scope, facilities or operators used Review whether prior registration or subsequent notice is required
Changes to general conditions Change of approved independent conditions Review whether approval is required
Transfer, merger, split or succession Succession to the operator’s status Confirm the required notice within 30 days
Discontinuance Discontinuance of the Type 1 business Notice generally required within 30 days

Cases Commonly Extending beyond the Registration Scope

Case Principal Cause Records to Check Decision Point Initial Response
Domestic factory pickup under Port-to-Port registration Domestic transportation is treated as a mere ancillary service Quotation, order, House B/L and truck agreement Whether the domestic stage was undertaken as carrier Review Type 1 motor-truck registration
Integrated domestic pickup and overseas delivery Difference between Type 1 and Type 2 is not understood Door-to-Door quotation, B/L and agency agreement Whether both preceding and subsequent collection and delivery are integrated Review Type 2 ocean permission
Domestic factory shown as Place of Receipt The document field is completed for sales convenience House B/L, collection contract and registration Whether responsibility begins at the factory Correct the document and registration structure
Overseas inland destination shown as Place of Delivery Agent work is confused with the operator’s responsibility House B/L, agency agreement and quotation Whether overseas delivery was undertaken for the shipper Review contract, foreign law, insurance and Type 2 classification
Sea & Air under one transport document International air registration is not reviewed Transport document, air freight, AWB and conditions Whether the operator undertakes the air stage Review international air registration
Independent B/L terms used after selecting standard conditions Application and sales operations are disconnected Business plan, standard conditions and B/L reverse terms Whether the actual conditions have approval Consider approval or correction of operations
Actual Carrier changed without procedure No regulatory change-control system exists Registration, shipping line agreement and booking records Whether registration or notification is required Consult the competent office promptly
Japanese registration described as mandatory for import forwarding Export and import regulatory scope are confused Direction of carriage and domestic contract Whether the operation is export, import or third-country Review only the relevant post-import domestic stage separately

Scenario 1: Port-to-Port Transportation from Yokohama to Singapore

Japanese Corporation A receives a 40-foot container at Yokohama CY, subcontracts ocean carriage to a shipping line and undertakes delivery at Singapore CY.

A collects ocean freight from the shipper and issues a House B/L stating Yokohama CY as the Place of Receipt, Yokohama as the Port of Loading, Singapore as the Port of Discharge and Singapore CY as the Place of Delivery.

A is the transportation contracting party for the international ocean stage. This is a typical Type 1 ocean operation.

Where the shipper separately arranges transportation to Yokohama CY and the buyer separately arranges delivery after Singapore CY, those stages are outside A’s Type 1 ocean contract.

Scenario 2: Transportation from a Factory in Mito to Singapore Port via Yokohama

Corporation A receives cargo at the shipper’s factory in Mito, subcontracts trucking to Yokohama and then undertakes ocean carriage to Singapore Port under one contract.

Collection exists only on the Japanese side. The operation is therefore generally not Type 2.

A nevertheless undertakes both the domestic motor-truck stage and the international ocean stage for the shipper. Type 1 motor-truck registration must be reviewed for the domestic stage and Type 1 ocean registration for the ocean stage.

If the House B/L states Mito City as the Place of Receipt, the domestic registration, truck contract, conditions and liability insurance must support responsibility from Mito.

Scenario 3: Integrated Transportation from Domestic Pickup to Inland Delivery in Singapore

Corporation A receives cargo at a warehouse in Saitama, arranges collection to Yokohama, ocean carriage to Singapore and delivery through an overseas agent to the buyer’s warehouse in Jurong under one Door-to-Door contract.

The contract integrates collection preceding the ocean trunk stage and delivery following that stage.

The operation is likely to fall within the Type 2 ocean definition and should not be conducted solely under Type 1 ocean registration.

The fact that the overseas agent performs the physical delivery does not remove the Type 2 issue where A remains contractually responsible to the shipper for final delivery.

Scenario 4: Sea & Air Transportation from Kobe through Busan to Singapore

Corporation A sells transportation from Kobe Port to Singapore Airport, with ocean carriage to Busan followed by air carriage to Singapore.

If A undertakes only the ocean stage and the shipper separately contracts the air stage, the operation may be reviewed primarily as Type 1 ocean transportation.

If A collects a through rate, issues one multimodal document and assumes responsibility through Singapore Airport, Type 1 ocean registration alone may be insufficient.

The international air registration, conditions for each mode and contractual responsibility must then be reviewed.

Common Misconceptions

Misconception Actual Position Review Point
Issuing a House B/L means that Type 1 ocean registration is always sufficient Type 2 or another mode may be required according to the responsibility stage Place of Receipt, Place of Delivery and actual contract
Type 1 ocean registration permits every Door-to-Door service Integrated collection and delivery on both sides may require Type 2 permission Both preceding and subsequent collection and delivery
Any domestic pickup makes the operation Type 2 One-sided collection generally requires a combination of Type 1 registrations Whether both sides include collection or delivery
There is one universal NVOCC license Registration and permission depend on mode and Type 1 or Type 2 classification Ocean, air, motor-truck and responsibility stages
Accounting net assets of JPY 3 million automatically satisfy the requirement The statutory basic asset amount excludes deferred assets and goodwill Basic asset calculation
Individual approval is required even when standard conditions are used Conditions identical to the standard ocean conditions are deemed approved Business-plan statement and actual conditions
Registration permits any business different from the original plan Changes to area, office and business scope may require procedure Change registration and notification
Japanese Type 1 ocean registration is mandatory for import NVOCC work Import and third-country international forwarding are outside that international regulatory scope Domestic stage after import
A shipping line quotation is the only required application evidence The business plan, facilities, finances, officers and conditions are also required Complete application set
All obligations end when registration is issued Tax, display, fare reporting, annual reports and change control continue Post-registration compliance calendar

Registration Classification Checklist

Situation for Confirmation Party to Contact Items to Confirm Response if a Problem Exists
Designing a new service Sales, legal and operations personnel Receipt, delivery, modes and period of responsibility Do not sell the service until the registration category is determined
Distinguishing Type 1 from Type 2 Ministry or competent office Whether both sides include collection and delivery Provide a service diagram and draft contract for prior consultation
Including domestic pickup Motor-truck forwarding office Which party undertakes the domestic stage Review Type 1 motor-truck registration
Offering Sea & Air Ocean and air forwarding offices Air-stage contracting party, freight and responsibility Review international air registration
Preparing the application Accounting, administration and officers Basic assets, offices, officers and disqualification Resolve deficiencies before filing
Contracting with the Actual Carrier Shipping line, NVOCC and legal personnel Contracting entity, route, freight and liability Match the agreement name with the applicant
Selecting general conditions Legal, insurance and competent office Standard or independent conditions Prepare an approval application for independent conditions
Preparing the House B/L Legal, operations and insurer Receipt, delivery, conditions and responsibility Correct wording exceeding registration or insurance
Commencing operations All departments Registration, conditions, quotations, billing and claims Implement SOPs and approval controls
Changing the service Competent office, legal and sales Area, office, scope, facilities and operators used Confirm change registration or notification before implementation
Annual compliance Accounting and compliance personnel Business overview and performance reports Manage deadlines in an annual compliance calendar

When to Consider Specialist Advice

An operator may prepare and submit an ordinary application itself or engage an administrative scrivener. Specialist review should be considered where:

  • The classification between Type 1 and Type 2 is uncertain
  • Domestic pickup, overseas delivery or several transportation modes are combined
  • Sea & Air, Rail & Sea or another multimodal service is undertaken under one contract
  • A Japanese corporation may fall within the foreign-operator definition because of its representative, officers or voting rights
  • Independent English House B/L conditions will be used
  • The standard conditions conflict with existing B/L reverse terms
  • The operator has already issued House B/Ls before obtaining registration
  • Past Door-to-Door operations may have exceeded the registered scope
  • A major casualty reveals a mismatch among registration, conditions and insurance
  • Administrative sanctions, suspension, cancellation or criminal penalties may arise

Consult the Ministry or competent office regarding forms, filing and classification; an administrative scrivener experienced in freight forwarding regarding application preparation; a maritime and logistics lawyer regarding contracts, conditions and regulatory response; and an insurer or specialist insurance agent regarding freight forwarder liability insurance.

Summary

Type 1 ocean registration permits a business to undertake export ocean freight forwarding from Japan by using another transportation operator while contracting with the shipper in its own capacity.

The typical scope is Port-to-Port transportation from a loading port in Japan to an overseas destination port. Where collection or delivery exists on only one side, separate Type 1 registrations for the relevant modes may be combined.

Where both collection preceding the trunk stage and delivery following it are integrated, Type 2 ocean permission must be reviewed. Sea & Air may also require international air registration where the operator undertakes the air stage.

The application requires a business plan, Actual Carrier relationship, offices and storage structure, a basic asset amount of at least JPY 3 million, absence of disqualification grounds and appropriate general conditions.

After registration, the operator must continue to manage registration tax, fare reporting, display, change procedures, annual reports, House B/L operation, overseas agents, liability insurance and claims handling.

Type 1 ocean registration is not merely an administrative certificate. It is the regulatory foundation for determining the transportation stage the operator undertakes as carrier and the documents, contracts, conditions and insurance supporting that responsibility.