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Census Should Remove' 'Duplicative' AES State Origin Element, Rename USPPI Field, NCBFAA Says

The Census Bureau should remove the state of origin data element in the Automated Export System and instead direct state governments and other partner agencies to use the state reported in the address of the U.S. Principal Party in Interest, the National Customs Brokers & Forwarders Association of America said in comments to the agency this month. NCBFAA said a separate data field for the data element is “unnecessary” because Census’ Foreign Trade Regulations already require that the originating state be reported in the USPPI address data field.

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“As such, AES reports contain duplicative information since the data fields for State of origin and USPPI address both identify where the goods began their journey to the port of export,” said NCBFAA, responding to a September Federal Register notice from Census that sought public comments on AES. “Since the USPPI address data field captures the originating state information, the State of origin data field may be removed without impeding Census’s data collection activities.”

NCBFAA also recommended Census rename the data field for USPPI address to “freight location” to “clarify the data element, reduce confusion within the trade community, and increase the accuracy of the reported address in the AES.” Renaming the data field would “clearly indicate to the USPPI and its authorized filer(s) that the address information to be reported is the location where the goods began their journey to the port of export,” NCBFAA said.