CBP Should Delay November ACE Deadline if Trade Not Ready, Says COAC

CBP should consider adjusting its implementation schedule for the Automated Commercial Environment if the trade community isn’t ready by the Nov. 1 deadline for mandatory filing, said the CBP Advisory Committee on Commercial Operations (COAC) in a formal recommendation adopted at its April 24 meeting. Under CBP’s current plans, filers that aren’t ready for ACE on Nov. 1 will have to file on paper as the Automated Commercial System (ACS) is shut down. COAC’s One U.S. Government at the Border Subcommittee said it is “concerned that reverting to paper will significantly slow the velocity of trade, especially given the pre-holiday peak season.”

CBP should base its ACE implementation dates on “periodic assessments” of trade community and partner government agency (PGA) readiness as the November deadline approaches, said the COAC recommendation. CBP should also collaborate with the trade community to develop a backup plan, it said. Only about 5 percent of filers are currently using ACE release, said Amy Magnus, who co-chairs the COAC subcommittee, at a recent conference (see 1504030026). According to the most recent data released by CBP for February, only seven entry filers filed over 10 percent of their entries in ACE (see 1503200021).

CBP should also expedite the finalization of the PGA message sets by “strongly encouraging” that PGAs don’t add new data element requirements that aren’t currently required at time of entry, said a second COAC recommendation. Avoiding such “data creep” would “ensure the timeliest receipt of the final data requirements and programming specifications” by the trade community in advance of the November deadline, said the recommendation. New data elements defined as optional or conditional, such as production dates, “should not impact the automated release of the goods,” it said.

The trade community needs ACE programming to be finalized “well before” the implementation date so that it has time for testing of new IT systems, said Mike Mullen of the Express Association of America in comments before the recommendation was adopted. Getting code a month or six weeks in advance would allow the trade community to identify bugs and get them worked out, he said.