Preparing for ACE Reautomation/Redesign of the Entry Process Under ESAR Release A2 (Part III - Reconciliation, Liquidation, Refunds, and Document Presentation)
In February 2006, two members of the trade community prepared a pamphlet entitled "Trade User's Guide for ACE-ESAR Release A2," in order to help current ABI/ACS customs brokers, self-filers, and their automation vendors focus on significant changes they might experience as ACE ESAR (Entry Summary, Accounts, Revenue, also referred to as ACE Release 5) is rolled out.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
(Although these two individuals are members of the Trade Support Network (TSN), they note that their pamphlet is not approved, endorsed, or sanctioned in any way by CBP or the Department of Homeland Security (DHS).)
This is Part III of a multi-part series of summaries of this pamphlet and contains excerpts from the pamphlet's sections on operational changes for Reconciliation processing, liquidation/closeout, refunds-increased duty bills, and document presentation. See future issues of ITT for additional summaries.
The authors state that the pamphlet focuses on what entry preparers and filers will need to prepare for the substantial changes coming with ESAR Release A2; currently expected in early 2008. Trade sources have previously stated that the byword for ESAR A2 should be "reautomate or perish" in light of the reautomation and, in some cases, redesign of the entry process which will occur with ESAR A2.
Reconciliation Processing
Under ACE, all flagging of an Entry Summary for reconciliation will be done at the line item level. Filers will still be able to set one flag for the entire Summary, but it will be the equivalent of flagging every line on that Summary.
Retroactive (after original submission of the Entry Summary) flagging for Reconciliation will be allowed and will be part of ACE Release A2. This will be accomplished using the post summary correction (PSC) process and will be at the line item level. A Reconciliation Entry must be filed once an item is flagged. There will be no canceling of flags or using PSC to remove a flag.
Under ACE, Reconciliation entries will be filed directly into the system. The offline spreadsheets and disks will be eliminated.
CPB is developing a test program under ACE to automatically handle an importer's entries that are subject to antidumping and/or countervailing duty (AD/CVD). Participating importers would flag AD/CV entry lines on their entries. A reconciliation entry is prepared with an entry number assigned by the filer. Once instructions are received from the Department of Commerce, it is expected that ACE will initiate the request for an AD/CV Reconciliation entry summary number, thereby simplifying the current process considerably.
(There are a large number of automation and operational issues that must be dealt with, as well as interagency agreements.)
CBP, after long discussions with the trade, will maintain the Aggregate Reconciliation program. A new transaction will be developed for mass "No Change" reconciliations to close out outstanding flagged lines that will not be changed. Canceling using PSC is not an option.
PSC will be used to make changes to a Reconciliation entry once it has been accepted by CBP.
Liquidation/Closeout
CBP is expected to change its liquidation process to save costs. Most entries will liquidate by operation of law one year from the Date of Entry. No courtesy notices of liquidation will be sent. Exceptions will include entries not automatically liquidated at the one-year statutory period and for increases, refunds, extensions, suspensions, etc.
Refunds - Increased Duty Bills
Increases and refunds, other than those that are offset (as related to PSC) will be processed as usual (weekly cycle, individual bills).
Document Presentation
ACE will provide for a full separation of the payment of any DTF from the process of submitting documentation to CBP. This applies to transactions individually paid, paid on Daily Statements or PMS, or where no payment is required.
ACE will allow for receipt of the required documents both by paper and through an acceptable electronic transmission.
(See ITT's Online Archives or 06/22/06 and 06/23/06 news, 06062205 and 06062310, for Parts I and II of BP summary of the Trade User's Guide.)
Trade User's Guide for ACE-ESAR Release 2 pamphlet (dated 02/09/06) available via email by sending a request to documents@brokerpower.com.