No Serious Issues for FDA's May 31 ACE Changes Despite Initial Concerns, Say Brokers, Developers
A recent deployment of changes to ACE filing requirements for the Food and Drug Administration on May 31 went smoothly, despite some concerns leading up to the deployment among the trade community, said customs brokers and software developers. Following the relatively uneventful passage of CBP’s May 28 deadline for certain cargo release entry types, import filers and developers on May 31 again reported only minor issues, with an outage that evening unrelated to the deployment and its timing coincidental, said FDA.
The deployment, which implemented FDA’s updated ACE filing rules from version 2.4.1 of its supplemental guide, included changes that were not compatible with previous versions of FDA’s filing requirements, said Fany Flores-Pastor, director-R&D compliance systems at Descartes. “The previous version of the message structure can no longer be used, some intended use codes will no longer be valid and new hard edits will be enforced,” she said. Worried the trade community did not have enough time to implement the changes, some developers and brokers had been asking for a grace period before CBP announced the deployment would be a “hard cutover” (see 1605130028 and 1605180059).
Nonetheless, the day went “very well,” said Craig Seelig, product manager at software developer Wise Tech Global. “I was quite concerned going in,” he said. “CBP gave us less than one week to test in their test system,” and “things were blowing up all over the place” in initial trials before CBP deployed fixes some days later.
The day was “eerily quiet,” said Chris Springer, director of operations at QuestaWeb. “In anticipation of the May 31 drop many of my filers, as they have done in the past, pre-filed as much as they could,” said Springer. “For our service bureau clients it was seamless,” he said. “No issues so far.”
Filers did see some hiccups in the form of blank messages for otherwise legitimate errors. Messages referenced an “Unknown Condition Code” with a valid error code, but not the usual text, said Sandra Langford-Coty, vice president-customs brokerage at OHL. Langford-Coty only encountered the issue once, “but many were experiencing the rejects,” she said. “The reject itself is valid, just the text is not and it is related to some sort of server issue. Overall for our entries it has gone relatively well,” said Langford-Coty.
Later that evening, FDA reported an issue with its Firm Management System that affected all FDA ACE entries and legacy Automated Commercial System entries that required prior notice (here). The issue was resolved and a backlog of messages processed by several hours later, said CBP in a subsequent message (here). Despite falling on the same day as May 31 deployment, the timing of the issue was a "coincidence and did not involve the ACE system at all," said an FDA spokesman. Instead, the problem was with the firm management system "that ACE queries in order to match the firm identifiers," he said. "The FMS system had a deployment which introduced a bug and created the issue, which has since been resolved," said the spokesman.
Meanwhile, the “consensus” among the trade community is that the May 28 deadline for cargo release entry types 01, 03, 11, 23, 51 and 52, as well as type 06 entries and entry summary, also “went well,” said Langford-Coty. On a call with filers and developers, “CBP mentioned that they stood up the war room over the weekend and only received three calls.” FDA entries and entry summaries for entry types 01, 03, 06, 11, 23, 51 and 52 will be required in ACE on June 15.