Trade & CBP Discuss ACE Action Items (Turning Off ACS, DIS, PGAs, AES)
In June 2011, CBP, the Trade Leadership Council and the Trade Support Network discussed key "action items" for developing ACE, including the plan for turning off ACS, the upcoming Document Imaging System pilot, the visibility problem with Post Summary Corrections for prior filers, and using ACE for export licensing and reports.
(The TLC consists of ACE trade ambassadors and trade co-chairs of the Trade Support Network (TSN) committees. The TSN is a group of trade representatives who provide input to U.S. Customs and Border Protection on the design and development of Modernization projects, such as ACE. See ITT's Online Archives or 07/26/11 news, 11072615, for BP summary of TSN’s approved changes to its ACE Priorities Document. See ITT's Online Archives or 06/27/11 news, 11062713, for BP overview of the background documents CBP had posted for the TLC conference.)
The following are highlights of the "action items" discussed at these events:
Turning Off ACS
Plan for turning off ACS. CBP noted that the plan for turning off Automated Commercial System (ACS) is still in progress and that it will work with the trade as decisions are made regarding the decommissioning of ACS.
Other entry types. Trade stated that the automation of all entry types is still a problem. Although entry types 01, 11, and 03 will be automated in Automated Commercial Environment (ACE), CBP will not have all entry types automated before ACS is turned off.
Document Image System
Surety & importer concerns. Sureties expressed concern that Document Imaging System (DIS)1 was developed without input from any of the TSN sureties. Importers also expressed their concern that they have no visibility to the images sent by the filer nor to the status of that documentation.
All summaries or just ACE. CBP noted that it is discussing, and will notify trade of its decision, whether DIS will be applicable to ACE filed entry summaries only or if DIS going to be applicable to all entry summaries.
Duty drawback. CBP will work with the trade on any future efforts to use DIS for Duty Drawback.
PGA message set/DIS pilots. CBP stated that it and Participating Government Agencies (PGA) plan for both the PGA Message Set2 and DIS pilot(s) and rollout plan to be discussed as part of the agenda for the next TSN Plenary Session scheduled for September 2011.
Automated Export Processing
DIS for export manifest, AES. The trade said it would like to be kept informed of the next steps related to automating the export manifest in ACE and interfacing with Automated Export System (AES) to get export license and report information. In response, CBP stated that it is currently evaluating the use of DIS as a short term solution for filing export manifest and possibly, export license information.
CBP also stated that it will continue to work with the trade through various TSN committees for both the effort to: (i) use DIS for filing export manifest documents; and (ii) on the long term effort to fully automate the export manifest in ACE. Providing there is interest, CBP stated that it would expand to other carriers and then reach out to the TSN International Trade Data System (ITDS) Committee and Export Committee.
Filing ITAR license info using DIS. The trade also indicated an interest in pursuing the use of DIS for filing International Traffic in Arms Regulations (ITAR) license information. CBP stated that it will work with TSN committees to follow up on this issue.
M1 as template for export manifest. CBP stated it is also evaluating the possibility of utilizing the inbound rail and sea manifest (M1) as a template for the export manifest, recognizing that additional data elements and indicators would need to be added for the export manifest and that some edit checks would need to be removed. CBP is also looking into building Air Manifest and Export Manifest concurrently.
Other ACE Priorities, PSCs, Cargo Release, EDI Message Formats
Allowing previous filer to see PSCs. There was discussion about developing a Great Idea Form (GIF) which would allow the importer to flip a switch which would allow a previous filer to see post summary corrections (PSCs) made by another filer. CBP stated it is in the process of drafting the language for the GIF which will include details/high level requirements.
Cargo release functionality. As additional PGAs get more information on cargo transactions, the trade stated that it would like to be informed so it can work more closely with CBP and the PGAs to keep the cargo release effort moving forward. CBP stated that it and the PGAs will coordinate or communicate this future cargo release functionality and issues with the trade.
Simplifying EDI message formats. In reference to a discussion on the current use of different Electronic Data Interchange (EDI) message formats for different modes of transportation, CBP has indicated that it was evaluating ways to simplify and standardize message formats to save costs and increase efficiency. However, CBP noted that it would hold future discussions with the trade before taking any actions on this issue.
1One of the three interrelated The International Trade Data System (ITDS) initiatives being developed is DIS. DIS will facilitate the automated submission of documents and specific data by trade participants to CBP. Transmitted documents will be processed and securely stored by CBP, and made available for review by CBP and PGAs via the DIS application.
2The establishment of the PGA Message Set is one of other two proposed ITDS initiatives to enhance automated interaction between CBP, PGAs and trade partners by facilitating electronic collection, processing, and review of trade documents filed during the cargo importation and release process.
TSN TLC June “Action Item” document available here or available via email by sending a request to documents@brokerpower.com.