COAC Urges Earlier Targeting of Export Shipments

CBP should "test out various methods for accomplishing the earliest possible targeting of export shipments" as part of the ongoing export manifest pilot, the Commercial Customs Operations Advisory Committee's export subcommittee said in recommendations adopted at the group's Feb. 28 meeting in Miami. The agency should also strive to "accurately measure the impact of late targeting on cargo carrier operations and the movement of legitimate cargo in order to facilitate a proper cost-benefit analysis for the regulatory rule-making," the group said in its recommendation.

Last year, CBP expanded pre-departure export manifest filing pilots for exports within ACE to more participants, and extended the testing periods to Aug. 10, 2018, for air cargo; to Sept. 21, 2018, for vessel cargo; and to Oct. 9, 2018, for rail cargo (see 1708110020). The agency should also use the pilot to "examine potential mechanisms to empower early inspection and the ability of forwarders and carriers to have input into the location for inspection, and to test the best candidates in real time," the COAC said in another recommendation.

The need for centralized account management for manifest compliance will only grow as "air will soon be subject to three individual electronic manifest regimes -- import manifest, Air Cargo Advance Screening, and export manifest," the subcommittee said. The agency could use volunteer carriers to work on a proof of concept for account manifest compliance, COAC said. The COAC also recommended that CBP work with [the Census Bureau] and carriers to "identify Post Departure Filers to participate in testing during the manifest pilot," it said. From there, CBP should start to use "in the nearest possible timeframe, the export pilot to validate the concept of a low risk exporter program as put forth in the Post Departure Filing proposal," the COAC said.

CBP "believes that much of the nation’s export security and enforcement needs can be moved
from the export filing requirements of AES to an export manifest process allowing the
continuation of the post departure exemption," the agency said in its COAC report on the post departure filing working group. A formal post-departure pilot will be announced "some time during" fiscal year 2018, CBP said. Discussions are ongoing between CBP, Census and the Bureau of Industry and Security about regulatory changes that "may be required for the implementation of the program."