COAC's Full Export Modernization White Paper Includes Appendices on FTR Changes

CBP’s Commercial Customs Operations Advisory Committee’s full Export Modernization White Paper includes a range of appendices that provide greater insight into how CBP and the COAC envision export modernization. The 127-page paper, originally issued as an abbreviated 24-page version in June, defines the roles and responsibilities of parties in the export process, dives further into export modernization recommendations and includes a range of areas in the Foreign Trade Regulations that will likely be revised. The other appendices include an analysis of Electronic Export Information data elements, information on post-departure filing and other documents produced by the COAC’s working groups.

Once the Census Bureau can “ensure that the data collected from the electronic manifest” can be used instead of EEI data, parts of the FTR will likely need to be updated and revised, according to the white paper, which was emailed this week by Brenda Barnes of the COAC Export Modernization Work Group and the Columbia River Customs Brokers and Freight Forwarders Association.

Commerce will specifically need to revise regulations surrounding carrier responsibilities, the white paper said. Several data elements, including date of export, port of exit and foreign port of unloading, “need to shift responsibility to the carrier.” CBP should also work with CBP to align its enforcement policies and mitigation guidelines “to consider the unintended consequences of the current enforcement environment regarding Electronic Export Information (EEI) and manifest data that often hinders the collection of accurate data,” the white paper said.

The white paper also includes “manifest education” packages for air, ocean, rail and truck transportation, detailing how export manifest is used for each, problems that need to be addressed and recommendations.