CBP Provides Some Detail on Coming ISA Pre-certification Pilot
CBP will soon launch a pilot test of the Importer Self-Assessment Pre-Certification Program (ISAPC) that will allow CBP-certified customs brokers to screen and vet applicants to CBP’s ISA program, the agency said in a report on the Advisory Committee on Commercial Operations (COAC) Role of the Broker Subcommittee. The report was released ahead of the Aug. 15 COAC meeting in Seattle. According to CBP with ISAPC, eligible ISA applicants will be approved for the program in 90 to 120 days rather than 9 to 18 months. The CBP Role of the Broker report is (here).
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As previously described, CBP is drafting a Federal Register notice to announce the program in full detail, but CBP’s initial program requirements for an applicant will likely:
- Be C-TPAT-certified for at least 3 years;
- Operate as a licensed customs broker representing importers as a filer (under the licensed broker’s filer code) for at least 5 years;
- Maintain written internal control procedures designed to ensure compliance with CBP-related activities;
- Have a history of compliance with CBP (i.e., no substantial penalties).
(CBP has said brokers who apply and are accepted into the Importer Self Assessment Pre-Certification Program (ISA-PC) will perform the comprehensive review of the ISA applicant’s package and evaluate the applicant’s readiness to self-govern and participate in the ISA program. The accredited broker will draft a final report on the applicant’s ISA readiness and submit it to the Partnership Programs Branch for processing and validation. If there are no anomalies, the report will be scheduled for ISA Review Board approval/certification.)
Following the pilot, CBP will evaluate the success of the program and make adjustments as necessary. At that time, CBP would also like to re-examine the exclusion of non entry-filing participants in the program and explore the possibility of certifying other customs professionals, such as consultants and academics. CBP previously said it expected to release a Federal Register notice this summer.
(The ISA is a voluntary program for resident importers that work with CBP to improve trade compliance. Those that have two years of importing experience and are certified in the C-TPAT program, are eligible. ISA participants take responsibility for self-assessment, and they must control their environment and activities by assessing risk areas and communicating, informing and monitoring their customs operations.)
(See ITT's Online Archives 12022425 for previous information from CBP on the ISAPC pilot. See 12080922 for a list of the COAC materials.)