NCBFAA Says it's Urgent & Desirable for CHBs to Join ACE Now

December 20, 2011 by Marie Rapport|Top News

The National Customs Brokers & Forwarders Association of America has issued a White Paper on the need for customs brokers to transition to ACE now, saying "it's necessary, it's desirable, and it's urgent." NCBFAA's Board believes that it is no longer a question of whether to migrate to ACE, but when, and states that it is not feasible to wait for ACE to be finished before attempting to use it, nor is it plausible to rely on it being abandoned. While much work remains to be done, CBP has recently begun to show good progress and has adopted essentially all of the recommendations for functional development outlined in the initial NCBFAA White Papers. It is time for the brokerage industry to support that development and accept the inevitable.

In its White Paper, NCBFAA states the following:

Must Join Now as ACS Modules to Be Decommissioned

Think of this in terms of survival -- as CBP rolls out new modules in ACE the corresponding module in ACS will be decommissioned and ACE will be the only system available for that functionality. Isn’t it better to work proactively and at a comfortable self determined pace for migration to ACE, rather than a reactive, mandated transition imposed by ACS decommissioning?

For example, M1 (Vessel and Rail Multi Modal Manifest) is scheduled to be released in January 2012 and CBP has already announced that the corresponding module in ACS for carriers and NVOCC's will be decommissioned—that is, put to sleep for good—in June 2012. That is less than 10 months from now!

Those that Join to Have Competitive Advantage

Consider that competitive advantages will begin to accumulate for those who begin transitioning to ACE now. Among other benefits, ACE already provides (1) Census override capability, (2) Post Summary Correction¹, and (3) Document Imaging to the ACE portal for non-RLF “Documents Required” messages, all of which are features NCBFAA has sought for years. Also, within ACE there is better data integrity for the ACE reports for both customs brokers and their customers.

While it may not be apparent to the trade, CBP is conducting more and more of its business in ACE. The Agency is committed to ACE; it will be the system of record for customs business and it behooves the brokerage industry to adopt ACE as well.

Additional Broker "Live Testing" is in CHBs Interests

Additional broker live testing is critical to fully debug the ACE functionality that will be used in the brokerage business. As more brokers utilize ACE, NCBFAA and CBP will receive critical feedback that will both inform and hasten further system development and improve functionality. Moreover, it is reasonable to hope that a possible consequence of increased commercial activity in ACE resulting from accelerated migration by NCBFAA members would be a more reliable funding stream, allowing for more timely development of the cradle to grave functionality we need.

Make no mistake about it, there is a tremendous amount of work yet to be done before ACE can finally serve as the single “system of record” for CBP and the trade, and we all know that the devil is in the details. There can be no doubt that NCBFAA will need to stay engaged with CBP and closely monitor the development and implementation of crucial releases, including eBond, Reconciliation, Export Manifest, Liquidation, Protests, Penalty Assessment and Mitigation, and other discreet elements of the customs process.

Time Has Come for NCBFAA Members to Begin Transition to ACE

NCBFAA states that it is encouraged by recent developments and the Board of Directors believes the time has come to encourage members to begin transitioning to ACE in a measured and well controlled manner. Learn how to process in the Automated Commercial Environment at your own pace while that opportunity remains. Begin to explore the advantages that already exist in ACE, and exploit competitive advantages as they begin to accumulate.

Immediate Benefits of ACE

What would transitioning to ACE mean to a broker? NCBFAA states that immediate benefits include:

Change from paper-based systems to electronic systems

Document imaging is a central feature of ACE
CBP makes requests to brokers via ACE Secure Data Portal instead of paper forms
Responses to CF 28s, 29s and 4647s can be submitted via the importer’s ACE Secure Portal if the customs broker is given access by the importer
Reports can be run for status on all CF 28s, 29s and 4647s
Blanket declarations (such as AD/CVD non-reimbursement statements) can be posted in ACE (The trade can direct a local CBP port to ACE if the port is requesting a copy of a blanket statement that has been filed in ACE)
AD/CVD case management, including reports and the electronic filing of documents are all ACE ready

Over 125 custom reports can be created

There is fast response and faster turn-around on entries

Increase in paperless entries

Census overrides

No paper submission with summary

Post Summary Corrections

Paperless submission of what is now a PEA

Cost savings

Fewer courier expenses
Lower administrative expenses
Lower copier and paper costs
Benefits available in the long term:

ITDS -- all PGA’s are connecting via one interface to CBP and the trade

Only one transmission of the data required for all agencies

Cargo Release is coming

Better information sharing between CBP, carriers and brokers

View shipment status and store data 24/7 via the ACE Secure Data Portal How to Transition to ACE

Start Testing Now, ACE is Coming on Fast

The Board of Directors is encouraging members to start testing in ACE in order to be ready when multimodal cargo release becomes functional next year. Experiment by choosing a single client for filing entries in ACE. The resulting increase in utilization and experience will allow members to make meaningful suggestions for better ACE development.

Confirm that the company's software provider has the programming ready for ACE. Then the company's ABI representative should be contacted to volunteer for ACE Processing. The NCBFAA ACE Strategy Task Group and Automation Committee has developed an ACE "How To” tool kit for its members and NCBFAA will continue to schedule webinars and provide updates as new functionality is developed.

Start slowly but get started now. ACE is coming on fast and everyone's business is going to depend on it.

¹NCBFAA expects that the “private”, “semi-private” data issue that is currently precluding an entry filer from accessing material PSC information relating to changes made by another filer will be largely resolved in the near term.