Integrated Manifest System, Redeveloped PSC Process Among Needs for 21st Century Customs, TSN Says

Improvements to the manifest system, Post Summary Correction and reconciliation functionalities are some issues that deserve attention from CBP in order to modernize the agency's trade processing, the Trade Support Network said in comments to CBP. Tom Gould, of the TSN's Trade Leadership Council and Sandler Travis, submitted the comments on behalf of the TSN in CBP's request for input on creating a new customs framework (see 1812200003). All comments are due Feb. 4 and only two other comments were filed in the docket as of Feb. 1. Maritime Exchange for the Delaware River and Global Coalition for Efficient Logistics also filed comments.

Among specific issues deserving updates, the TSN cited the manifest system. "A fully-integrated manifest system across modes and across import/export systems is required, one that allows seamless intermodal movement and visibility, full house-bill functionality for all modes, and accurate real-time transfer and tracking of in-bond shipments," the TSN said. "Such developments would allow ACE to meet the letter and spirit of EO 13659, with regard to the reduction of supply chain barriers to commerce while continuing to protect U.S. national security, and the promotion of economic competitiveness through enhanced trade facilitation and enforcement. While a number of independent manifest improvements have been made by CBP, and implemented by the trade at great expense, the promise of ACE as a full multi-modal, end-to-end system has not yet been achieved."

The TSN also pointed to Post Summary Corrections as an area needing improvement. "There is a need to redesign the Post Summary Correction functionality for Trade and CBP efficiencies," it said. "The TSN sees an undue burden being placed on the trade to comply with needlessly complicated processes and perceives that this is a situation where the system is driving the policy, not the other way around." That's also true of the quota system, it said. CBP should also close all gaps in reconciliation functionality and make it a permanent program, the TSN said.

There's also several improvements to be made in data sharing, including beyond just with the importers, Gould said. "Data-sharing with trade parties other than importers is of critical importance," the TSN said. "Maximum visibility provided to carriers via ACE reporting and ACE messaging is critical to allow them to aid CBP enforcement goals through improved oversight of what moves via their networks, and when and by whom, in real time." CBP should also "share collection data, payment data, penalty data, liquidated damages data and electronic documents uploaded via DIS with importers," it said. Importer Trade Activity (ITRAC) reports should also be available in ACE, the group said.