CBP Posts Report on Recent ACE Release 5 Workshops

(These workshops are attended by members of the Trade Support Network (TSN), called Trade Ambassadors, who are importers, brokers, carriers, and other members of the trade community.)

The following are highlights of CBP's summary of six ACE Release 5 workshops held from June 7, 2005 to June 16, 2005:

Summary Declaration - June 7, 2005.CBP states that this workshop on the summary declaration addressed issues including the entry summary declaration, daily statement, and proposed mechanisms in cases where documents are required.

With regard to entry summary declaration, CBP indicates that the trade's comments included (partial list):

In today's environment, until the statement comes in (that is 10 days after entry), the trade has unlimited chances to make corrections without concern for "fault" and that it would like CBP to maintain this policy.

The trade also indicated that they would like to avoid a two step approach (i.e., submission of CF 3461 and then follow with CF 7501); the trade prefers to submit the CF 7501 if they have all the information - this would be a "declared CF 7501;" it is unlikely that the trade would recertify this.

The trade also repeated that it would like an open period up to the 10^th day with the ability to do a full replace or make changes up until then.

According to the summary of this workshop, CBP's decisions are as follows:

CBP will still allow a two-step process;

when the CF 7501 comes in the first time (after the CF 3461), the CF 7501 will be considered the declaration;

after CF 7501 declaration, changes would be in post summary corrections mode; and

this will be a test so the rules can change to accommodate the test and that most of these changes are not impacting admissibility.

The trade responded to CBP's decisions by expressing the following concerns:

That some of these corrections might impact admissibility (e.g., classification)

This new policy should be announced to the trade with assurance that changes within the 10 day period would be considered "no harm no foul"

If this is not done, it would have a chilling effect on the trade community and there would be reluctance on the part of the trade to make these corrections early

The reprogramming that will be required for post summary corrections will be close to what was required for the original entry programs and that this may require the trade to redo their entry programs.

Regarding the issue of proposed mechanisms in case where documents are required, CBP notes that exceptions would be documents that CBP requires to be physically reviewed (e.g., a visa with an embossed seal) and that those documents will continue to be processed as paper.

The trade commented that although it still needs a resolution on a number of factors, CBP should go forward with its vision of accepting scanned documents.

Post-Summary Corrections - June 8, 2005. This workshop addressed the issues surrounding post-summary corrections. According to CBP's summary, the known higher-level business rules include:

1. corrections will be allowed for 183 calendar days from the "date of entry;"
2. any corrections filed after this date must be accompanied by a request for liquidation extension;
3. "declaration" is the trigger for entering post summary correction;
4. only entry types 01, 06, and 31 will be processed via post summary corrections; and (There will be three new entry types defined for foreign trade zone (FTZ) processing related to quota and AD/CV processing. The 06 will represent the non-quota and non-AD/CV consumption entries from a FTZ.)
5. Supplementary Information Letters (SILs) and Post Entry Amendments (PEAs) will no longer be processed at the ports and all changes must be made via the post summary correction process. SILs and PEAs effectively go away with the introduction of this process.

AD/CVD - June 8, 2005. This workshop on AD/CVD addressed issues such as blanket flagging for reconciliation entry, administrative review, bond obligation, the filing of the reconciliation entry, etc.

USPPI/FF Accounts - June 14, 2005. The focus of the U.S. Principal Party in Interest/Freight Forwarder (USPPI/FF) workshop was on creating and maintaining USPPI/Authorized Agent (consistent with new Census regulations, freight forwarders are referred to as "Authorized Agents") in ACE and developing master account data. The trade will be able to establish their account and account structure of ACE and only be able to view their master account data. CBP states that the workshop would not discuss process or transaction functionality.

One of the issues addressed in this workshop was if a USPPI changes the address, who makes the change.

Warehouse Accounts - June 15, 2005. The purpose of the warehouse accounts workshop was to discuss the creation and maintenance of bonded warehouse accounts, operators, CFS, and CES. CBP states that it would not address transactions. According to CBP, it was to discuss who provides the data, the account structure, the maintenance of the data, designating what are mandatory and optional data elements, account specific reports, etc.

FTZ Accounts - June 16, 2005. The FTZ account workshop addressed issues such as creating a new FTZ account, existing zone set up, creating new FTZ account processes, FTZ data elements, statuses, sub-zones, sites, "zone tab," zone users/applicant, TSN requirement ENT 043, maintaining the FTZ account, and reporting.

June 6-17, 2005 Trade Engagement Biweekly Report (Report No. 12) available at

http://www.cbp.gov/linkhandler/cgov/toolbox/about/modernization/trade_support_network/report_workshop/report_08222005.ctt/trade_08222005.doc.