Pre-Departure Export Manifest Filing Could Save Trouble on Consolidated Shipments, CBP Official Says

Coming pre-departure electronic manifest filing requirements will make life easier for exporters with consolidated shipments, said Jim Swanson, director of cargo controls at CBP’s Office of Field Operations, at the East Coast Trade Symposium on Dec. 2. Getting shipment data earlier in the supply chain will allow CBP to target shipments before they are packed into containers, saving exporters the expense of having containers holding their shipment unpacked so CBP can look at an unrelated shipment, he said. Pre-departure manifest filing could also make “Option 4” post-departure filing in the Automated Export System an easier proposition for CBP to swallow, he said.

The effort comes more than a decade after advance import and export information was required by the Trade Act of 2002, Swanson said. Though it met the requirement for imports, CBP only began pilots of pre-departure export manifest filing in 2015 (see 1507090011, 1508190007 and 1509080017). Once it completes the pilots, CBP will move to mandatory pre-departure manifest filing “as soon as we possibly can get there,” Swanson said. That will require a regulatory change, he said.

The goal of pre-departure manifest filing is to get shipment information as soon as possible, Swanson said. The non-vessel operating common carrier (NVOCC) or forwarder would send it to CBP “as early as cutting the bill,” transmitting basic data like the shipper, consignee, description of the commodities and an internal transaction number (ITN), if required, he said. As the shipment moves through the supply chain the information would be updated, adding what flight or ship and what container it’s in, Swanson said. That will allow CBP to track the shipment through the supply chain, giving the agency the ability to hold risky shipments before they are consolidated with others, saving the cost and time of unpacking containers and avoiding missed sailings, he said.

Pre-departure manifest filing could also save AES Option 4 filing, Swanson said. Following enactment of the 2002 Trade Act’s advance data mandates, CBP decided it could no longer let exporters file Option 4 post-departure. However, after discussing the issue with the trade, CBP has found its opposition to Option 4 was “more of a beginning position.” The goal is now to “eliminate post-departure-only information,” he said, meaning post-departure filing of some data may be allowed.