First Phase of CBP DIS Test for Importers and Brokers Detailed

U.S. Customs and Border Protection plans to begin a test of the Document Image System (DIS), said a April 6 Federal Register Notice that provided details of the test's first phase. The test will allow importers and brokers that use the Automated Commercial Environment (ACE) to file certain government forms through the Electronic Data Interchange (EDI).

Documents Supported During the First Phase

The CBP forms and commercial documents supported in this first phase of the DIS test and covered by the notice are Commercial Invoices, Packing Lists, and Invoice Working Sheets. The Participating Government Agency (PGA) related forms and documents supported in this first phase of the DIS test and covered by the notice are:

• TSCA Import Certification Form
• EPA Form 3520-21 Importation of Motor Vehicles and Engines (off road)
• EPA Form 3520-1 Importation of Motor Vehicles and Engines (on road)
• EPA Form 3540-1 Notice of Arrival of Pesticides and Devices
• EPA Pre-approved Vehicle/Engine Exemption Letter
• EPA Pesticide Label
• APHIS Ingredients List
• APHIS Phytosanitary Certificate
• APHIS Import Permit
• APHIS Transit Permit
• APHIS Notice of Arrival 7
• APHIS Pre-Clearance 203
• NOAA Form 370 Fisheries Certificate of Origin
• NOAA Toothfish Pre-Approval

Rules for Submitting Images in DIS

The following rules will apply to all participants involved in the DIS testing process:

• Documents may be transmitted in DIS in response to a request for entry summary documentation or in response to a request for release documentation for certified ACE entry summaries.
• Unsolicited document submissions are not allowed; but for the purposes of PGA forms and invoices/packing lists that are associated to ACE entry summaries certified for cargo release, the trade may submit the required documentation without a prior request by CBP or the PGA.
• Only documents that have been requested by CBP or the PGA should be transmitted to CBP. If a document is submitted that has not been requested by CBP, an error message will be returned indicating that the transaction for which the document was submitted does not have any pending document requests made by CBP or a PGA.
• The filer may only file documents that CBP can accept electronically. In this first phase of DIS, the documents CBP can accept electronically are noted below. If CBP cannot accept the additional information electronically, the filer must file the additional information by other means, which may be paper.
• For the purposes of this test, original documents must be retained and made available in paper, if requested by CBP or a PGA.
• For the purposes of this test phase, APHIS, EPA and NOAA forms can be submitted only with ACE entry summaries that are certified for release.
• Authorized CBP and PGA users will have the ability to access document images submitted by trade participants via a user interface, which will allow CBP and PGA users to select specific documents for review, to change the status of documents, and to add comments based on the current state of their review. Subsequent deployment phases of DIS will extend the functionality developed in this first phase to other CBP and PGA systems. The latter phases will incorporate additional forms into DIS and provide new interfaces for integration of DIS with other systems in CBP and other government agencies. The exact dates and content of subsequent phases of DIS have not been determined but will be announced in the Federal Register when set. All data submitted within the ACE Portal will be considered confidential, except to the extent as otherwise provided by law. Participation in ACE tests isn't confidential and upon a written Freedom of Information Act request, a name(s) of an approved participant(s) will be disclosed by CBP.

Technical Specifications for Document Submission

Images must be submitted in an XML via Secure FTP, Secure Web Services, existing EDI ABI MQ interfaces. All responses back to the importer and/or broker will also be sent in the form of an XML message. There are no technical restrictions on the Multipurpose Internet Mail Extension (MIME) file types that DIS will accept; however, JPEG, GIF, PDF, MS Word Documents, and MS Excel Spreadsheets are preferred.

Test Evaluation by Participants

To ensure adequate feedback, participants are required to participate in an evaluation of this test. CBP also invites all interested parties to comment on the design, implementation and conduct of the test at any time during the test period. CBP will publish the final results in the Federal Register and the Customs Bulletin as required by 19 CFR 101.9(b). The following evaluation methods and criteria have been suggested:

1. Baseline measurements to be established through data analysis.

2. Questionnaires from both trade participants and CBP addressing such issues as:

• Workload impact (workload shifts/ volume, cycle times, etc.).
• Cost savings (staff, interest, reduction in mailing costs, etc.).
• Policy and procedure accommodation.
• Trade compliance impact.
• Problem resolution.
• System efficiency.
• Operational efficiency.
• Other issues identified by the participant group.

In order to be eligible to participate in the DIS test, importers or brokers must be ACE entry summary filers. Interested participants should contact their client representative for additional information pertaining to participation in this test. Interested companies that do not currently have an assigned client representative should submit a Letter of Intent expressing their intent to participate in the DIS test so that client representatives can be assigned. Instructions for the preparation of the Letter of Intent can be found on the CBP Web site (here).

(See ITT's Online Archives 12040534 for initial summary announcing this CBP notice.)