CBP Posts COAC Updates on Trusted Trader, C-TPAT Export Programs

CBP posted some more documents from the July 29 Advisory Committee on Commercial Operations (COAC) meeting. Among the documents is the presentation from the event (here), which outlined all the COAC recommendations, including calls to delay some deadlines for use of the Automated Commercial Environment for cargo release and entry summary filing (see 1507290066).

CBP also posted issue papers on various issues. The issue papers include information on the below:

• COAC Pipeline Working Group (here)
  The movement of petroleum and natural gas products through pipelines presents unique challenges to CBP. Lack of specific regulations in 19 CFR, unique infrastructure for measuring and monitoring and limited automation to date has resulted in an inconsistent, location-by-location approach to the industry by CBP. Additionally, each pipeline operator uses company specific documentation for importations, movement of shipments and accounting procedures. The working group will develop an action plan meant to establish procedures consistent with other modes of transport, provide an audit trail for pipeline movements, and ensure that the proper amount of duties and taxes are accounted for.
• Electronic Air Export Manifest (here)
  The July 10 notice opening a test for ACE manifest filing for air cargo exports was to begin the application process and have authority to collect the data, said CBP. CBP has assured this group that all of the items will be discussed prior to actual collection of the data as operational and business procedures are developed. The COAC voiced some concerns with the test on July 29 (see 1507310012).
• ACE/Single Window (here)
  CBP is deploying 14 PGA Single Agency Pilots on Aug. 19, with aggressive expansion phases in August and September to both validate the PGA capabilities and prepare CBP and PGA field resources. These pilots will initially be deployed in the first pilot phase at 12 ports of entry.
• Border Interagency Executive Council (BIEC) (here)
  ​The focus for the coming year will be for U.S. agencies (particularly those with the ability to hold cargo at the border) to get access to, and use, advance information, such as manifest, to target high-risk cargo prior to arrival or departure, CBP said. The agencies should also develop mechanisms or capabilities to enhance communication of agency-specific risk factors; and, build “business rules” in the system to automate targeting for common risk factors.
• C-TPAT Export (here)
  Among the ongoing challenges is a lack of benefits, said CBP. Export enforcement agencies such as Commerce, State and Census, already offer mitigated penalties, leaving little room to offer C-TPAT exporters additional benefits through their agencies.
• Trusted Trader (here)
  CBP is awaiting approval from the Office of Management and Budget (OMB) for the revised information collection requirements for the Trusted Trader Program. Once OMB clearance is granted, CBP can begin to transition the existing ISA members to the Trusted Trader Program. As of July, there are 328 ISA members.
• Option 4 (here)
  AESDirect filers can use the pilot once CBP takes over AESDirect in Fall/Winter 2015. CBP is seeking a limited data set prior to departure for the export transactions in order to conduct screening and make informed risk assessments of export shipment, with the balance of data elements provided on a post-departure basis as eligible. CBP is looking at the electronic export manifest to support being able to conduct risk assessments under a future Option 4 program.