CBP and COAC Discuss Upcoming COE Account Based Processing Pilot
The COAC Trade Facilitation Subcommittee met with U.S Customs and Border Protection officials on June 15, 2010 to discuss one of CBP’s top Account Based Processing projects -- Centers of Expertise.
(In May 2009, COAC submitted to CBP a white paper advocating a broad new ABP concept that would encompass trade compliance, informed compliance, security, intellectual property rights, import product safety, and information technology.
One of COAC’s recommendations was the establishment of COEs for specific industry sectors at certain ports, with the goal of achieving more industry commodity expertise, greater uniformity of treatment of specific product categories, and promote informed compliance.)
COE Concept Discussed by the Subcommittee
The Subcommittee spent most of its time discussing CBP papers related to ABP and COEs. Discussion topics noted in the minutes include the following:
Concern that Account Management was being deemphasized. One Subcommittee member expressed concern that the Account Manager position may be falling by the wayside as CBP fleshes out a COE concept; he wanted to be sure that some central point (virtual team) would be able to review the entries. A CBP official responded by stating that she did not want to limit where the entry can be filed, but that the virtual team should be accountable for every step of the process.
Account Management favored over COEs by BACM. A Subcommittee member noted that at a recent Business Alliance for Customs Modernization (BACM) meeting, the group said they were more in favor of pursuing Account Management than COEs. Another member pointed out that the two positions could be reconciled, because the goal of a COE was to build upon the Account Management process.
Different opinions on whether pilot should be voluntary or mandatory. It was suggested that the group pick an industry sector for the pilot and then ask for volunteers. One Subcommittee member stated that he thought that a company should either be a part of the program or not, it should not be the importer’s choice.
CBP says COE pilot(s) will work out issues of concern. The CBP official noted that one or more COE pilots will work out all the issues of concern, such as which port the goods are flowing through.
NY NIS, Finance Center, Drawback Center Added as COEs, Not OGAs
During the June 15, 2010 meeting, the Subcommittee provided additional feedback to CBP on possible COEs and pilots. Although one COAC member suggested a COE pilot for Other Government Agencies (OGAs), the rest of the Subcommittee thought that would be difficult and decided to hold off. In addition, a CBP official suggested the Natural Gas and Oil Pipeline Process as a possible COE pilot.
The Subcommittee added Commodity Specialists, National Import Specialists in NY, National Finance Center, Drawback Center, and the Labs to its list of “successful” COEs.
(During a previous meeting, the Subcommittee proposed to CBP that COEs be the top priority CBP ABP project. Possible COEs previously discussed by Subcommittee were Miami’s processing of cut flowers, CBP’s drawback centers, National Finance Center, and centralizing the processing of entry summaries. The Subcommittee stated that it would provide input to CBP on additional areas where they think CBP could have a COE.)
See ITT’s Online Archives or 05/11/10 news, 10051125, for BP summary of the Subcommittee’s March-April 2010 meetings.
See ITT’s Online Archives or 03/16/10 news, 10031605, for BP summary of CBP’s discussion of COEs at the February 2010 COAC meeting.)