Preparing for ACE Reautomation/Redesign of the Entry Process Under ESAR Release A2 (Part V - Post-Summary Corrections)
In February 2006, two members of the trade community prepared a pamphlet entitled "Trade User's Guide for ACE-ESAR Release A2," in order to help current ABI/ACS customs brokers, self-filers, and their automation vendors focus on significant changes they might experience as ACE ESAR (Entry Summary, Accounts, Revenue, also referred to as ACE Release 5) is rolled out.
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(Although these two individuals are members of the Trade Support Network (TSN), they note that their pamphlet is not approved, endorsed, or sanctioned in any way by CBP or the Department of Homeland Security (DHS).)
This is Part V of a multi-part series of summaries of this pamphlet and contains excerpts from the pamphlet's section on operational changes for post-summary corrections. See future issues of ITT for additional summaries.
The authors state that the pamphlet focuses on what entry preparers and filers will need to prepare for the substantial changes coming with ESAR Release A2; currently expected in early 2008. Trade sources have previously stated that the byword for ESAR A2 should be "reautomate or perish" in light of the reautomation and, in some cases, redesign of the entry process which will occur with ESAR A2.
Post-Summary Corrections
The intent of the PSC is to replace the paper Supplementary Information Letters (SILs) and Post Entry Amendments (PEAs) with an automated system to make corrections to entry summaries that have already been filed.
Once the Entry Summary data is accepted by ABI and the goods are released, the PSC process must be used to make any corrections.
- CBP is requiring an audit trail of all changes and versions.
- Exception - a PCS cannot be used to resolve a matter that has been flagged for Reconciliation.
- A "full replace" may be used until the goods are released. If Entry Summary data is initially ABI rejected, it is not necessary to use a PSC to correct the summary.
PSC will be handled in ACE similar to an underlying Entry Summary. Once ABI accepted, the PSC can also be routed within CBP to the appropriate party (anywhere in the U.S.) for review and a decision.
- No subsequent correction can be submitted for an Entry Summary until the previous correction has been resolved financially (i.e. paid/ appeared on a final daily or monthly statement).
PSC will be allowed for both header and line item changes.
- Most data fields can be changed using PSC including the participating government agencies data. A list of fields that cannot be changed will be developed.
- Reason codes will be required for each change. Specific reason codes are currently being developed and will probably include a general category with a more specific suffix.
Lines cannot be replaced when using PSC.
- Entry lines can be deleted. The deleted line number cannot be re-used.
Census Override codes will be sent using the PSC.
PSC will be the vehicle to flag a line for reconciliation if it was not done at the time of initial summary filing.
- However, PSC cannot be used to remove a flag. This must be done by filing a reconciliation entry.
CBP will not limit the number of PSCs that can be filed for an entry.
- See the rules limiting non-clerical error duty refunds below, though.
- After 183 days from the date of entry, PSCs must be accompanied by a request for a one-year liquidation extension. The request will be sent as part of the PSC. PSCs filed during CBP's 2-week liquidation processing cycle will be rejected.
The current ABI processing allows for an unlimited number of replacements to the CBP-7501 data within the 10-day window after release. Under ACE this will not be allowed and all changes to the CBP-7501 will be visible to CBP.
- Today a large percentage of releases are made by certifying release from CBP-7501 data (one-step processing). Under ACE, filers may want to consider using the two-step process in situations where they may not have all necessary information at the time of release.
The "clerical error" duty refund issue:
- Changes as a result of "clerical errors" will be allowed as often as necessary.
- PSC refunds resulting from other than "clerical errors" may trigger the immediate liquidation of the Entry, with the refund being issued at liquidation.
This is because 520(a) only allows refunds prior to liquidation for clerical errors.
The TSN Legal/Policy Committee is supporting legislation that would allow the use of PSC and pre-liquidation refunds for all corrections.
Note - CBP does not, at this time, expect to use PSC for handling Prior Disclosures.
CBP is expected to allow PSCs to be used for the following entry types: 01, 02, 03, 05, 06, 07, 08, 09, 11, 12, 21, 22, 23, 24, 25, 26, 31, 32, 34, 38, 51, and 52.
Entry types not included are:
- 04 - Appraisement
- 33 - Aircraft & Vessel Supply
- 41-46 - Drawback
- 61 - Immediate Transportation
- 62 - Transportation and Exportation
- 63 - Immediate Exportation
- 64 - Barge
- 65 - Permit to Proceed
- 66 - Baggage
(See ITT's Online Archives or 06/22/06, 06/23/06, 06/27/06, and 06/28/06 news, 06062205, 06062310, 06062715, and 06062810, for Parts I-IV.)
Trade User's Guide for ACE-ESAR Release 2 pamphlet (dated 02/09/06) available via email by sending a request to documents@brokerpower.com.