NCBFAA Details Ongoing ACE Issues in Letter to CBP

The National Customs Brokers & Forwarders Association of America recently called on CBP to address several holes that still remain in ACE. “While CBP has made great strides over the last few years in development of ACE, we are still in need of additional critical development to make ACE functional,” the trade group said in a white paper. An attached “Priority List” lays out the specific needs of the trade community and where CBP is in addressing them. The group raised similar issues in a Feb. 9 letter to Brenda Smith, executive assistant commissioner in the CBP Office of Trade, obtained by International Trade Today

Over the past several weeks, the NCBFAA has held a regular conference call to discuss ACE issues with members of the trade community, including software developers, importers, self-filers and customs brokers. Several issues and concerns emerged over that period, the trade group’s letter said. Biweekly ACE “technical calls” are held too infrequently for how little time remains before CBP’s Feb. 24 ACE deployment, the letter said. Often on those calls, CBP officials say a ticket has already been opened on an issue “and discourage what they view as multiple tickets,” which limits CBP’s understanding of how widespread a problem may be, it said.

CBP also needs to be more transparent and predictable with its schedule of updates to CBP and Trade Automated Interface Requirements (CATAIR) updates, and provide more lead time for testing by the trade community of programming changes, the letter said. The Feb. 24 ACE deadline includes drawback, reconciliation and liquidation (see 1707270038), as well as new e-bond and Cuba import filing capabilities (see 1802080023).

More broadly, CBP needs to improve ACE to be “robust, stable, operational, and fully encompass all aspects of filing entries for the purpose of being the system of record of international trade,” according to the NCBFAA white paper. For example, CBP should “stabilize the release date coding within ACE,” which is currently “not capable of consistently providing a stable release date for goods clearing the border.” ACE must also “be enhanced to provide a data pipeline big enough to handle the size of transactions that are required by the needs of business in a single filing” by removing the current limit of 999 lines or a megabyte of data.

The agency must also improve its ACE messaging, the NCBFAA white paper said. “The messaging system currently in place in inconsistent, duplicative, prone to incorrect interpretation by CBP and the trade, not self-explanatory in any way, and despite repeated requests from the trade, no complete list of messages and their meaning has ever been provided to the trading community from CBP. This creates uncertainty and confusion about what certain messages mean and how they are consistent with other seemingly identical messages,” it said.

The NCBFAA’s Priority List says work continues on several needs identified as critical. “CBP is currently working to determine a proposed automation solution for the collection of [Section 321] entries and partner government agency (PGA) data,” and is collaborating with the NCBFAA on a “'trade interruption plan’ which we expect will provide guidance for CBP and brokers when there are system-performance issues,” the list said. Work is “underway” to implement a non-ACE solution for ensuring currency exchange rate data,” and “for the time being, currency conversation information will continue to be provided via ACS,” it said. The list also mentions that “CBP is planning to maintain current [Importer Trade Activity] ITRAC reports for the foreseeable future,” despite some concern that the capability would be eliminated with the ACE transition (see 1601250041 and 1710130025).

"CBP maintains an active dialog with the trade community and appreciates the feedback it receives from stakeholders like NCBFAA," a CBP spokesman said in a emailed statement. For the upcoming Feb. 24 deployment, "CBP will continue the practice of working closely with NCBFAA and other trade stakeholders as we move through the transition period," he said. "Further information on the ACE deployment and post deployment support can be found at https://www.cbp.gov/trade/automated. Additional details on the deployment will also be sent out to subscribers via the Cargo Systems Messaging Service (CSMS)," he said.

Email ITTNews@warren-news.com for a copy of the letter.