CBP Holds, Form 28s Identified Among Top Challenges in First COAC Trade Survey
CBP exams and holds on goods are among the largest difficulties among importers and brokers, according to the first Trade Efficiency benchmarking survey, released Aug. 8. The survey, done in June by the Advisory Committee On Commercial Operations (COAC), is meant to be a look at CBP's trade facilitation and effect on lowering costs of compliance. The survey was among a large set of COAC materials released by CBP. (See 12080922 for a list of the materials.)
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The new report summarizes survey responses in three areas: Centers of Excellence and Expertise, Stops and Effects, and Participating Government Agency (PGA) Interaction and CBP satisfaction. This survey established benchmarks for the importing process including both the time and money spent throughout the lifecycle of an entry. For example, a one-day delay in the release of merchandise costs companies over $700 for each affected shipment, according to the survey. A company’s in-house cost to respond to a single CBP request for information on an entry (CF-28) ranges from $300 to over $700, in addition to external costs, such as brokerage services, the survey said.
Top Facilitation Challenges
The survey also provided qualitative data on facilitation concerns. Several of the biggest facilitation challenges remain exams and or holds, followed by CF-28s, it said. Among importers, exams are considered the most important trade facilitation concern, with CBP and PGA holds close behind. Licensed brokers put CBP and PGA holds as the top two on their list of concerns and CBP and PGA processing times a close third and fourth, respectively.
The survey specifies the difference between the time spent for a CBP hold or exam and a PGA hold. The survey found the first 24 hours as critical in trying to resolve the issue, after which the hold is more likely to be extended to multiple days, it said. Respondents overwhelmingly pointed to the "ability to file all required data electronically for U.S. imports" as the most pressing issue for the Single Window Initiative to solve, with 75 percent describing it as "very important." Some 90 percent of importers agreed full electronic filing was the biggest issue, while licensed CHBs said "receiving PGA decisions through the same channels as CBP decisions," is the top issue. About 56 percent of respondents said between 0 and 1 percent of their cargo was stopped in 2011, while 27 percent said 2-3 percent was stopped.
High Praise for CBP
CBP largely won high praise for its responsiveness in addressing broker issues, the survey said. The survey showed CBP to have a good level of customer service at the ports when issues arise. Specifically, 53 percent of the respondents said most issues are communicated in 30 minutes or less and over 90% of the time the end result was positive versus a 9 percent a “not-positive” response.
COAC distributed the anonymous survey to various networks, including trade associations, importers, brokers, attorneys, consultants, freight forwarders, using a secure web-based tool and import service providers were asked to respond on behalf of their collective, averaged customer base, said the report. The survey had 521 respondents, with 41 percent identifying themselves as importers and 15 percent as licensed customs brokers.
The respondent makeup was:
- Importer (299) -- 41%
- Broker (63) -- 9%
- Customs Compliance Officer (83) --11%
- Licensed Customs Broker (110) --15%
- Consultant (22) -- 3%
- Customs Attorney (13) -- 2%
- Accounting or Financial Officer (8) -- 1%
- Logistics Officer or Supply Chain Officer (54) -- 7%
- Freight Forwarder (43) 6%
- Other (42) 6%