Developers Concerned Over Tight Deadlines for New Aluminum Filing Requirements

Software developers voiced concerns March 16 over whether they can meet a tight April 10 deadline for new country of smelt and cast information on entry summaries for aluminum products (see 2303090060). Speaking on the agency’s bi-weekly ACE trade call, developers urged CBP to develop a “work around” in the event that trade systems aren’t ready on the effective date of the new requirement.

CBP’s release of programming instructions on March 13 and 14 leaves software developers only “18 working days to code for this,” a developer on the call said. The problem is that the new requirements are complicated, asking for “either a country code or the letters N/A if no country exists for the first two” countries of smelt “and then a country for the third” data element, country of cast, the developer said.

“The user is never going to get that right if it's just the open text field that they need to key in,” the developer said. “So this is not something where you just add a drop down list to add the code and then they could put in the information. This is way more complicated than it needs to be. And because of the complication, it's going to take us time to do this,” he said.

“The time frame is unrealistic for the trade to have this done and working,” another trade participant on the call said.

Developers noted that the proclamation had been issued on Feb. 24 (see 2302240006), meaning 18 calendar days passed that developers could have been working on the new requirements before they were released to the trade community. And CBP had knowledge and was working on their own programming before the proclamation was issued, according to both trade and CBP participants on the call.

They said CBP could have given developers more time to program the complicated new requirement by allowing software developers to work in parallel. “Even though it’s not much, at least it would have helped,” another developer said.

CBP officials said that they were constrained by the tight deadlines in the proclamation. While they have promised developers 90 days to program before new ACE requirements take effect, in this case the agency was bound by the deadlines set in the proclamation, and they could not announce what was planned before the president himself issued the proclamation, CBP officials said.

“I understand where you're coming from,” one CBP official said. “You guys have to program this, you have software updates that you have to use on your end,” she said. “But you know, it's out of our control as well in some instances, in some cases, because it's the date that the president signs the proclamation and it's the date that it's effective in that proclamation,” the official said.

Another developer said the trade community nonetheless needs to know “what we do in case this doesn’t work out, if the software vendors are not ready for that day.” And going forward, she said, CBP needs to stress in internal government discussions that new filing requirements can’t be put in place “in a blink of an eye.”