PGA 'Lack of Understanding' of FTZ Reporting Adds to NAFTZ Concerns for ACE Timeline

The National Association of Foreign Trade Zones (NAFTZ) continues to have major concerns with the schedule for mandatory use of the Automated Commercial Environment, it said in a Dec. 8 letter to CBP Commissioner Gil Kerlikowske (here). A "general lack of understanding" related to FTZ reporting among the Partner Government Agencies adds to the trade association's worries for ACE, it said. The NAFTZ made a number of its concerns known in a letter last month that called for a delay to parts of the ACE rollout (see 1511190017).

Since the NAFTZ submitted that letter, it learned from CBP "that due to a general lack of understanding of the weekly FTZ entry/entry summary process and requirements, some PGAs are requesting that CBP transmit data sets at the time of both FTZ entry and FTZ entry summary," the NAFTZ said. "This could have a significant detrimental impact to the FTZ program, where the vast majority of FTZ user/importers file weekly entries and the consequences of having potentially double PGA holds, examinations or “documents required” on both filings would effectively halt FTZ operations entirely." CBP didn't comment.

As a result, CBP and PGAs should work with the NAFTZ "identify the best point of PGA data set transmission for the FTZ environment prior to mandatory use of ACE for Type 06 FTZ entries." Under the current schedule, CBP plans to require FTZ reporting for 06 entry/entry summary procedures in ACE beginning Feb. 28, including for the Food and Drug Administration, the National Highway Traffic Safety Administration and Lacey Act submissions. The association "respectfully requests that CBP and the first set of PGAs scheduled to receive data via ACE on February 28" meet together soon so "NAFTZ and its impacted member companies can work with CBP and the PGAs directly to identify the best point of transmission," it said. The association also released a set of Frequently Asked Questions related to ACE (here).