CBP Details its Proposal for Simplified Release & Summary at Sept TSN Meeting
The Trade Support Network’s Integrated Communications Subcommittee1 issued an overview and held a recent press conference on the TSN plenary held on September 22-23, 2011. During the plenary, CBP discussed a two-part “simplified entry” proposal which includes simplified release (subset of ISF + some additional data) and simplified (periodic) summary.
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(In August, CBP announced that a Simplified Entry, Summary, & Financial Workgroup, comprised of members from both government and industry2, has been tasked to create models for a streamlined entry/entry summary, as well as financial processes, that reduce the administrative burden of CBP procedures, while employing risk management principles that facilitate legitimate trade. . The two-part proposal for “simplified entry” resulted from those efforts. See ITT’s Online Archives or 08/15/11 news, 11081505, for BP summary of CBP fact sheet/presentation on simplified entry.)
Highlights from the overview and press conference on this concept include the following:
Simplified Release
Release on Subset of ISF Data + Some Add'l Elements
According to the subcommittee’s summary, under CBP’s proposal for Simplified Release, a reduced list of data elements would be submitted to obtain the release of goods. These data elements would be a subset of those found on the Importer Security Filing (ISF) today, plus some additional data elements. The additional data elements mentioned were the 10 digit HTS number, estimated value, and entry number.
In addition, the matching of certain manifest details beyond the bill of lading identification would no longer be required in order to file for release.
Release Decision Earlier in Process
The importer or the importer’s agent would submit the required data as early as available, and CBP would then provide a release decision earlier in the process that it currently does.
Pilot Expected Soon, Could Serve as a Base Piece for ACE Release
CBP is planning to pilot the simplified release concept shortly and a Federal Register notice is currently being prepared. CBP further noted that this pilot is high on the Commissioner’s priority list, and that the pilot could support, rather than detract from ACE cargo release, and could even serve as a base piece of it.
Participants in Pilot Would Have to be C-TPAT Tier 2 or 3, Etc.
The requirements for the pilot would include:
- must be a Customs-Trade Partnership Against Terrorism (C-TPAT) Tier 2 or 3 member to participate;
- the ISF importer must be the same as the importer of record and have a continuous bond on file;
- the port of arrival, unlading, and entry on the manifest would have to be the same; and
- the entry summary would have to be filed in the Automated Commercial Environment (ACE).
In addition, CBP expects the pilot to be open to air and ocean modes and, at least initially, exclude other government agency-applicable goods, and sub-house bills. Once the pilot is up and running and the concept and functionality of simplified release have been tested, CBP plans to expand the pilot’s scope and types of participants.
Simplified Summary
Single Submission for a Period of Time
Simplified Summary is the second part of CBP’s Simplified Entry proposal and would involve the creation of a single entry submission for imports over a period of time (rather than the current system of a single entry submission for each received shipment).
Firms Would Have More Time to Perfect Data
The idea of this proposal is that companies would be given a longer period of time with which to collect/perfect the data related to import shipments. For example, a company might choose to make a single monthly filing after the close of the accounting books for that month, with less need for follow-up and corrections.
1Integrated Communications is a subcommittee of the TSN Transition Committee. The TSN 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.
2Including importers, brokers, carriers, and association representatives. Key participants include: the ACE Business Office, Office of International Trade, the American Association of Exporters and Importers (AAEI), Commercial Operation Advisory Committee (COAC), National Customs Brokers and Forwarders Association of America (NCBFAA), etc.
(See ITT’s Online Archives or 09/16/11 news, 11091618, for BP summary of October 4, 2011 COAC meeting where simplified entry will also be discussed.
See ITT’s Online Archives or 08/10/11 news, 11081013, for BP summary of the USCIB and AAEI request to CBP for “Next Gen” C-TPAT (10+2 release, zero exams).)
Subcommittee summary available by emailing documents@brokerpower.com.