International Trade Today is a Warren News publication.

Sept 2011 TSN Meeting to Discuss Priority ACE Summary Edits, Etc.

The Trade Support Network1 will be meeting on September 22-23, 2011 to continue discussions on the development of the Automated Commercial Environment. One of the many topics that will be covered is the priority ACE entry summary edits needed by the trade, and CBP’s new “filter” concept for meeting this need.

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.

CBP Says both 24 High Priority ACE Summary Edits & “Compensating Controls” too Costly

In 2007, CBP said that 63 current Automated Commercial System (ACS) edits specific to the commercial preparation of the entry summary would not be carried over into ACE2. TSN reviewed and evaluated CBP's proposal and responded with 24 groups of edits that members believed were critical to keep. U.S. Customs and Border Protection then created a private/public task force in 2010 on these 24 groups of high priority edits.

In February 2011, CBP stated that it was looking at “compensating controls” as an alternative to the TSN’s 24 groups of high priority edits, as they thought such controls could be deployed and would be beneficial from both a cost and scheduling perspective.

However, in July 2011, CBP officials stated that implementing such controls would be almost as difficult and costly as installing the high priority edits themselves, and were as a result similarly unachievable.

Now Looking at "Upfront Filter" as Cost Effective Way to “Edit”

CBP officials stated that instead of edits or “compensating controls”, the agency was now exploring an upfront filter that would be applied just before the data goes into ACE. In July 2011, CBP began exploring the concept with its Office of Information and Technology (OIT), and was hoping that a data filter would provide acceptable results in a quicker and more cost effective manner.

CBP Asks TSN to Prioritize 24 Edits for an Upfront Filter

CBP sources stated that TSN members would be presenting CBP with an ordered list of priority edit recommendations at the September 2011 TSN meeting, so CBP would know which were the top priority to implement via the filter, in case there was not enough funding for all 24 of the high priority edits.

1The Trade Support Network is a group of trade representatives who have been providing input into CBP’s design and development of ACE since May 2001. TSN consists of members of the trade community, including trade associations, importers, brokers, carriers, sureties, and others.

2CBP's 2007 proposal was originally called “Edit Lite” and is also referred to as "Edit Modification."

(See ITT’s Online Archives or 12/21/10 news, 10122124, for BP summary of TSN’s concerns about ACE summary edits and its wish list for document imaging.

See ITT’s Online Archives or 02/15/11 news, 11021531, for BP summary of CBP’s statement that it has no funding to implement 24 priority ACE edits.

See ITT’s Online Archives or 07/26/11 news, 11072615, for BP summary of the TSN’s approval of changes to its ACE priorities.