NCBFAA Urges CBP to Withdraw Additional Data Elements Proposed for Form 7501

The National Customs Brokers & Forwarders Association of America recently urged CBP to pull back proposed new data elements on CBP Form 7501 for steel and aluminum imports, noting the information is already provided to the Commerce Department through that agency's import licensing programs and could be obtained from Commerce directly without any added burden to the trade.

"It is crucial to consider the reasonableness of requiring the trade industry to submit redundant information," the NCBFAA said in comments dated June 20. "CBP’s proposed revision to collect license information at the time of entry represents a slippery slope wherein hundreds of other agency licensing or permit information likewise could eventually become required customs entry data elements, making the entry and clearance process much more cumbersome." The NCBFAA also said that this runs "completely contrary" to the objectives of CBP's 21st Century Customs Frameork.

The comments came in response to a notice issued in April by CBP seeking comments on the newly required data elements before it submits them to the Office of Management and Budget for approval. For some steel tariff subheadings, CBP would require data on the country where the steel used was melted and poured. For aluminum, CBP has since May 10 required data on the countries where the largest and second largest volume of primary aluminum was smelted and the country where the aluminum was most recently cast.

"The proposed requirements include data elements that are already being provided to the Commerce Department by virtue of their licensing requirements as mentioned in the Notice," the NCBFAA said. "These required import license numbers are currently transmitted to CBP as a condition for release. We firmly believe that CBP has an opportunity to streamline the data collection process and retrieve all required information from relevant agencies, such as the Commerce Department," it said.

Another issue with the new data requirements is the duplication of data in both electronic format and paper format. Form 7501 is a "paper-based approach" that is "archaic and hinders the efficiency of importation processes," the NCBFAA said. Thus, the NCBFAA urged CBP to "embrace modern technology and fully transition to electronic submission methods." This transition would "significantly reduce paperwork burdens and enable faster and more accurate data exchange between importers and CBP," the NCBFAA said.

The NCBFAA also noted the environmental impact that adding this requirement would have. "The collection, storage, and transmittal of data has both an economic and environmental cost for both CBP and trade," the NCBFAA said. "By establishing effective data sharing mechanisms, the need for redundant submissions, including country of source and cast provided in steel and aluminum licenses, could be eliminated."

The proposed change also is "a regressive step in terms of automation," the NCBFAA said. "As the industry moves towards ACE 2.0, it is imperative to align initiatives with the goal of enhanced automation and streamlined processes without duplicative data."

CBP did not immediately respond to a request for comment.