COAC Meeting Overview: Broker Reform, Acct Mgmt Progress, ACAS Expansion, Etc.
On August 18, 2011, a COAC1 meeting was held in Long Beach, CA where CBP and COAC members discussed plans to develop recommendations for broker reform by October, roll out full-blown Centers for Excellence and Expertise in October, pilot simplified entry and financial process in October, expand the air cargo advance screening pilot to additional types of carriers and countries, and add export processing to the Automated Commercial Environment.
An overview of the meeting includes the following topics:
CBP and DHS
Recommendations for Broker Reform Expected by Oct
In January 2011, CBP established a “Role of the Broker-Broker Regulatory Revision” Workgroup to explore the concepts of an expanded broker role, broker responsibilities, professionalism, regulatory modernization, and penalty/regime disciplinary actions. CBP is expected finalize its recommendations and submit them to the Commissioner in October.
Implementation of Full-Blown CEEs for Pharma/Electronics Expected in Oct
CBP official stated that CBP has extended its two management by account pilots (the Centers for Excellence and Expertise (CEE) and the Account Executive (AE)) until October 1, at which time CBP intends to implement full-blown CEEs for the pharmaceutical and electronics industries. CBP is now developing its rollout plans and is seeking COAC input.
Plans to Pilot Simplified Entry and Financial Process in FY 2012
CBP officials also provided COAC with an update on another management by account issue -- simplified entry and financial process. According to CBP, the next steps are the finalization of proposals to be submitted to the Commissioner in October 2011, and the approval and piloting of models in FY 2012.
Next Steps for Air Cargo Advance Screening Pilot Include Forwarder & Country Expansion
CBP and COAC continue their work on the implementation and expansion of the Air Cargo Advanced Screening (ACAS) pilot (which began after the Yemen incident). The next steps for ACAS include expansion for the passenger-forwarder component, beginning August 29; and express consignment operator expansion of the pilot country list incrementally by highest threat regions.
Update on M1, Cargo Release, ACE Export Processing, Etc.
At the meeting, a CBP official gave an update on CBP’s ACE projects in development, including plans for full M1 deployment in Winter 2012, beginning the Cargo Release design and acquisition phase in early 2012 (assuming funding is available), and CBP's desire for ACE to be the single processing platform for all export manifest, commodity, licensing, and export control transactions in keeping with the President’s National Export Initiative and the Export Control Reform Initiative.
CBP Officials, Trade Discuss AD/CV Problems, Including Retrospective Nature
CBP has created a multi-discipline Re-Engineering Dumping (RED) Team to develop an operational protocol to frame the import process for entries subject to AD/CVD. The team is looking with special interest at transshipment, undercollections, the role of shell companies, and other gaps/vulnerabilities/challenges. Concerns about the retrospective nature of the AD/CV system were expressed by both CBP and COAC.
DHS’ Global Supply Chain Security Strategy Still Undergoing Review
During the introductory remarks, a DHS official discussed the status of DHS’ Global Supply Chain Security Strategy. According to DHS, the plan is still being reviewed and revised by the National Security Staff (NSS).
COAC
Land Border Subcommittee Is Working on Various C-TPAT Issues
COAC’s Global Supply Chain Security Land Border Subcommittee has been focusing on four areas: (i) how to strategically grow Small and Medium Enterprises participation in C-TPAT; (ii) 3PL, Cross dock and warehouse C-TPAT participation, (iii) C-TPAT Tier 3 for truck carriers, and (iv) outreach to the Border Trade Alliance on promoting Mexico’s Programa Alianza para el Comercio Seguro/Alliance for Secure Commerce in concert with C-TPAT.
One “U.S. Government at the Border” Initiative Considers PGA Issues
COAC’s One U.S. Government at the Border Subcommittee is focusing on creating a document on current practices that lead importers to provide repetitive/redundant data to CBP and PGA’s, and that require the sending of documents in multiple formats to the government. After this document is developed and presented to CBP, the details will be shared with the Border Interagency Executive Council and work will begin on documenting a partnership program that can be recognized by CBP and the PGA as a secured trusted shipper.
COAC Is Working on Issues Related to CBP’s 5 Year IPR Strategy
COAC’s IPR Enforcement Subcommittee has been working to address the facilitation area of CBP’s 5 Year IPR Enforcement Strategy.
Materials from COAC’s Aug 18 Meeting Available Online
CBP has posted materials presented at the August 18, 2011 meeting, available here.
1The Departmental Advisory Committee on Commercial Operations of U.S. Customs and Border Protection and Related Homeland Security Functions (COAC)
See future issues of ITT for more detailed summaries on many of the issues addressed in this overview.