New Entry Data Requirement for Chinese Postal Code Set for Deployment in ACE Dec. 15

CBP plans to add a new mandatory data element for entries of goods that originate in China as part of its efforts to enforce the Uyghur Forced Labor Protection Act. The agency will on Dec. 15 deploy a new “UFLPA Region Alert” capability in ACE, a CBP spokesperson said Oct. 26, making “postal code” a “required field” when “Country of Origin is China for Entry and for Manufacturer Identification Code (MID) creation,” according to a recent update to the agency’s ACE development schedule.

The new ACE capability will use the postal code data element to generate “a warning message when a Uyghur region postal code has been provided,” and also will generate an error message “if the postal code provided is not a valid Chinese postal code,” said the deployment schedule, which lists a deployment date of November. The CBP spokesperson did not give a reason for the delay until Dec. 15, but said communications about the revised date will be "going out by the end of this week."

CBP plans to put out “updated CBP and Trade Automated Interface Requirements (CATAIRs) and an Information Notice” by Nov. 3, and will add the capability to the ACE certification environment on Nov. 8 to allow “trade users to test the new feature and advise CBP of issues,” the spokesperson said.

“CBP is also planning further discussions with the trade community about the proposed change to be sure we understand the potential impacts,” the agency spokesperson said. “As always, if we learn from these discussions that the trade community has issues or concerns with the planned changes or deployment date, CBP will work to resolve those or change the deployment date as needed.”

"Requiring this new data element upon entry (i.e., the postal code for Chinese manufacturers) is a big change that will impact a significant number of U.S. import transactions,” customs lawyer Ted Murphy said in a blog post earlier on Oct. 26. “It would seem that such a meaningful change, particularly one that has such a large potential to disrupt/delay legitimate trade, would have been announced more widely and would provide a longer lead time for importers,” he said.

Murphy noted that the development schedule is “'a notional schedule’ of prioritized and funded ACE enhancements and is subject to change,” but said “one would have thought this would have been socialized with the trade community more.”

“Companies who import articles from China should be reviewing this new requirement and planning for it (or something like it) to go into effect at some point soon,” Murphy said.