COAC Presents its "Green Lane" Benefits Proposal to CBP
At its December 1, 2005 meeting, the Departmental Advisory Committee on Commercial Operations of Customs and Border Protection and Related Functions (COAC) presented its proposal for certain "green lane" benefits for Tier 3 Customs-Trade Partnership Against Terrorism (C-TPAT) members.
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According to the Hong Kong Trade Development Council (HKTDC) and other sources, the following were COAC's proposed "green lane" benefits:
Authorization to remotely file all types of entries;
Paperless entries for all imports except those requiring paper documents to meet other agency requirements;
Expedited processing of drawback claims;
Lower limit of liability on single transaction and continuous entry bonds;
Elimination of all security inspections (with some exceptions);
Expedited response (10 days rather than 30) to ruling requests;
Different guidelines for mitigation of penalties;
Ability to file multiple suffixes to the same nine-digit IRS number for purposes of the periodic monthly statement;
Reduction or elimination of CF 28 information requests - CBP inquiries would instead be handled through the company's national account manager;
Expedited background checks;
Elimination of penalties for late duty payments, which would be subject to interest only; and
Ability to take corrective action or make a prior disclosure of a violation before CBP seizes goods or issues fines and penalties.
U.S. Customs and Border Protection (CBP) responded to COAC's proposal by noting that it was an aggressive and comprehensive list of ways to change procedures and that it was "fairly visionary".
However, CBP noted that while certain of the proposed changes could be implemented in a reasonable time, CBP could not do all of the changes on its own.
COAC notes need to improve C-TPAT validation process, etc. At the December 1, 2005 meeting, COAC also noted that there is a need to improve the validation process in order for it to be done more quickly.
In addition, COAC encouraged CBP to recognize the benefits that the trade brings to C-TPAT.
HKTDC notice (dated 12/22/05) available at www.tdctrade.com/alert/us0525d.htm.