CBP Posts FAQs on M1 In-Bond Transactions, Will Stop Form 7512 Perforations

CBP posted a set of frequently asked questions (FAQ) about the use of in-bond within e-Manifest: Rail & Sea (M1). As of Oct. 1, M1 is the only electronic means to provide CBP advance ocean and rail manifest information.

(See ITT's Online Archives 12100212 for summary of the transition to M1.)

FAQs Provide Information on In-bond Closure, Form 7512s, Etc.

The document provides questions and answers on the closure of an in-bond and the use of Form 7512s. FAQs are as follows (partial list):

• How will closing of an in-bond move be handled in ACE?
  • CBP says arrival and export processes will remain the same under M1. Electronic transmitters responsible for transmitting the arrival and export of in-bonds as part of a business arrangement, will continue to do so, said CBP. CBP Form 7512 will continue to be accepted and processed under current rules.
  • CBP holds the bonded carrier whose bond has been obligated by the transaction responsible to report arrival, export and any changes to the in-bond or bill of lading. If a broker/filer is submitting the transactions on someone else’s behalf they will be held to the standards expected of all data transmitters. Transmitters are required to provide the most accurate information available and provide proof that they have done so. Deliberate false information may lead to civil and criminal penalties against the responsible party. Liquidated damages for violations of in-bond requirements will be issued to the bonded carrier.
• Will CBP still honor a request to perforate documents when third parties (terminals/warehouses/etc.) require a perforated CBP Form 7512 to pick up cargo moving in-bond?
  • During the M1 transition, port processes will remain the same. However, it is anticipated that CBP will no longer accept, stamp or perforate CBP Form 7512s in a fully automated environment. Trade partners will need to develop alternate processes that support the fully electronic environment.
• How is the unknown bill of lading for warehouse withdrawal Transportation and Exportation (T&Es) and Foreign Trade Zone (FTZ) T&Es done in ACE?
  • ACE will not generate a false Bill of Lading. For in-bond movements from Warehouses, FTZs, General Order (GO) facilities and Seizure facilities, said CBP. CBP Officers will be able to create a Bill of Lading (BOL) using the Facilities Information and Resources Management System (FIRMS) code and the in-bond entry number for paper in-bonds submitted for shipments that do not have active bills of lading. Any shipment that has not been entered but is still covered by the original arrival bill of lading should reference that bill.
• How will CBP Form 7512s be handled from a seaport to an airport?
  • When the bill is moving within the same port of entry, an electronic Permit to Transfer (PTT) will be used. When moving between different ports of entry, an in-bond may be required. Under the current regulations and port processing rules, a CBP Form 7512 will be submitted to CBP for input and processing as currently done in today’s environment.

Subsequent In-bonds

• How are subsequent in-bonds handled in ACE?
  • CBP says if a business practice is to transmit one in-bond covering multiple bills of lading, transmission of any subsequent in-bond will need to await the arrival of all the merchandise covered by that in-bond. When a subsequent in-bond QP is transmitted in ACE prior to the previous in-bond’s complete arrival, the QP transmission will receive the error ‘Prev Inbond Move Must Be Arrived’ (error code 181). This is the indication that the previous in-bond has not been arrived in its entirety.
  • To prevent this situation, carriers and in-bond filers should work together to come to agreement on a solution that allows for the freight to move when necessary. In this situation CBP has identified at least two solutions:
    • 1. Carriers may transmit the initial in-bonds at the Bill of Lading level and arrive them at their destinations at the same level. This will allow for all processing to continue at the port of destination;
    • 2. Carriers may continue to submit master in-bonds but arrive the shipments at the in-bond level. This will allow for processing of the subsequent legs. Carriers will be responsible to show that all of the shipments covered by the in-bond have actually arrived at the destination and are fully accounted.
  • CBP notes this change in process doesn't apply to export of in-bonds or Permits to Transfer.