NCBFAA Outlines ACE Transition Issues for Importers and Exporters

The National Customs Brokers & Forwarders Association of America remains worried about the number of software updates related to the Automated Commercial Environment so close to the mandatory use date, it said in a "open letter" to importers and exporters on Jan. 8 (here). Just as CBP decided to push back some of the mandatory use dates for ACE in response to readiness concerns for the system (see 1509010017), "we face the same decision now," said the trade group. The agency must immediately cease all software changes for processes that will be required in ACE as of Feb. 28, said the association.

While the trade group reiterated its dedication to the move toward ACE, the NCBFAA is somewhat skeptical of CBP's assurances ahead of the transition. "We have said that live testing of software by importers and exporters, by brokers and forwarders, by software providers, and by CBP jointly, without any further changes whatsoever, demand a minimum of sixty days," the trade group said. "Customs now says that its work is complete; the facts, however, suggest otherwise." The group pointed to software and system updates issues "on almost a daily basis." Notably, "some entry functions (such as the process for placing goods in a bonded warehouse), will not be available until the last minute, February 28th, the transition date."

A "dead stop" to the software updates is necessary "so that software developers can field a final product and so that we, and you, can adapt our own automation systems to these new ACE functions, sufficiently test that software through use in an operating environment and work in partnership with our customers to develop business processes to successfully transition to the new system requirements," it said. The CBP Advisory Committee on Commercial Operations similarly recommended a freeze on changes to Partner Government Agency requirements in the run up to the Feb. 28 mandatory use date (see 1510300018). CBP didn't immediately comment.

The Jan. 8 open letter, meant for clients of NCBFAA members, is a follow-up to a November letter that laid out the areas of concern surrounding the ACE effort (see 1511020006). "In order to avoid unprecedented delays and unnecessary out-of-pocket expenses, developmental work -- to include meaningful testing and process development by the private sector -- must be completed before use of the new system is mandated and the existing system is terminated."