CBP Urges Trade Cooperation to Deal with In-bond Policy Changes
The September transition to Automated Commercial Environment (ACE) M1 for rail and sea has "highlighted a necessary policy change that CBP has implemented to gain greater control over in-bond shipments," said CBP in its October ACEopedia. The agency will now require the arrival of the full shipment before a subsequent in-bond movement, the agency said. The change is a result of a three programming edits related to the transition from AMS to ACE and were meant to better track in-bond movements, CBP said in a recent set of Frequently Asked Questions (FAQs.)
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(See ITT's Online Archives 12100212 for summary of CBP's successful transition to M1. See ITT's Online Archives 12100921 for a recent interview with CBP's Brenda Smith regarding the transition.)
Under the new policy, "if a subsequent in-bond is transmitted in ACE prior to the previous in-bond‘s complete arrival, ACE will generate an error message," said the document. "To prevent this situation, carriers and in-bond filers need to work together to come to agreement on a solution that allows for the freight to move when necessary."
The new policy is causing some problems with those who "have become accustomed to transmitting subsequent in-bond transactions after the arrival of the first container only," the agency said. "CBP has implemented this change due to the need to implement more control over in-bond shipments, and is working with the trade on how to manage this modified requirement." CBP will "continue to look for ways to improve this process and is assessing the impact of this change in order to achieve better control over in-bonds while minimizing impact on trade movement. Now that ACE M1 is deployed, improvements are being identified and prioritized." it said.
Trade Mitigation Steps
CBP offered some ways to facilitate the movement in-bond shipments in a recent set of ACE M1 FAQs (here).
- Carriers can transmit the initial in-bonds at the Bill of Lading level and arrive them at their destinations at the same level. This will allow for all processing to continue at the port of destination.
- Carriers can continue to submit master in-bonds but arrive the shipments at the in-bond level. This will allow for processing of the subsequent legs. Please note that as always, carriers will be responsible to show that all of the shipments covered by the in-bond have actually arrived at the destination and are fully accounted for.
Simplified Entry Expansion
The ACEopedia also said CBP will again expand its Simplified Entry pilot to airports in Memphis, Anchorage, Alaska and Detroit. CBP recently expanded the pilot to ten other airports: Seattle, San Francisco, Oakland, Los Angeles, Dallas/Ft. Worth, Houston, Miami, JFK, Newark and Boston.
Other updates include:
(The "ACEopedia" also lists the deployed Automated Commercial Environment (ACE) capabilities and their dates as (1) ACE Secure Data Portal (2003), (2) Periodic Monthly Statement (PMS) (2004) , (3) e-Manifest Truck (2007), (4) ACE Entry Summary (2009), (5) Post Summary Corrections (PSC) (2010), (6) Importer Security Filing (ISF) (2009) with the link to ACE delivered in 2011), (7) e-Manifest Rail and Sea (April 2012), and (8) Cargo Release/Simplified Entry (May 2012), (9) PGA Interoperability (September 2011), (10) Document Image System (April 2012).)
Ranked ACE Priorities and Work Plan
In the ACEopedia and (here) are CBP's table of ACE Priorities and Work Plan. In its seven categories of work, CBP has completed projects in two categories to date (Manifest and Entry Summary). There are some changes on the table of priorities from the last ACEopedia. The ACE M1status was changed to "complete." Also, "Cargo Release/Simplified Entry Pilot Phase 1," is now listed as "in progress."
CBP's completed ACE projects are in italicized text below, while Priority projects and their ranking (1 - 5) are in bold. Projects that are remaining for ACE completion are in normal text.
| Category | Functionality |
| Manifest | e-Manifest: Truck |
| Delivery of ACE e-Manifest: Rail and Sea (Rank 1) | |
| Air Manifest | |
| Integration of Multi-Modal Manifest | |
| Vessel Management System | |
| Cargo Release | Cargo Release/Simplified Entry Phase 1 (Rank 2A) |
|---|---|
| Document Image System (Rank 2B) | |
| PGA Message Set (Rank 2C) | |
| Complete Delivery of PGA Interoperability (Rank 2D) | |
| Future phases to build upon delivered functionality for ultimate full delivery of cargo release (Rank 2E) | |
| Entry Summary | ACE Accounts and Reports |
| Periodic Monthly Statement | |
| Entry Summary Filing for Consumption and Informal Entries | |
| Antidumping/Countervailing Duty Entry Filing and Processing | |
| Post Summary Corrections | |
| Entry Summary Edits (Rank 3) | |
| Remaining Entry Summary types and processing | |
| Mail Entry Writing System | |
| Importer Activity Summary Statement/Simplified Summary | |
| Drawback | |
| Reconciliation | |
| Protest | |
| Entry liquidation | |
| Exports | Exports (Rank 5) |
| Financial | Integration of all financial capabilities within ACE |
| Operations/Maintenance | Priority fixes (Problem Reports) (Rank 4) |
| Ongoing fixes and enhancements to deployed functionality | |
| Rehosting efforts for ACS | |
| Rehosting efforts for AES | |
| Reducing cost of O & M | |
| Transition to the target architecture & open standards | |
| SEI assessment & integration planning | |
| Other | System Migration (LIMS, SEACATS, etc.) |
New ACE Development Funded in FY 2012 from Carryover Dollars
The ACEopedia continues to say that in fiscal year (FY) 2012, the ACE program entered into the Operations & Maintenance phase with no funding for additional development. The program is using carry-over dollars (from prior years) for development work on the following initiatives:
- Cargo Release/Simplified Entry (partially funded)
- CBP ITDS Priorities -- Document Image System (DIS), PGA Message Set, and PGA Interoperability
- Requirements efforts for Exports and to begin development of Exports
Unless future funding is available for continuous development of new capabilities, CBP states that development work will cease.
(The Automated Commercial Environment (ACE) is a multi-year project to modernize Customs’ processes, and will become the “single window” for all trade and government agencies involved in importing and exporting. ACE has been underway for over 10 years.
The October 2012 ACEopedia contains sections titled: Executive Summary, ACE overview and business case, ACE deployed capabilities, ACE program priorities, New ACE Development Strategy, e-Manifest rail and sea (M1), cargo release, exports, ACE budget/financial status, and frequently asked questions.)
(See ITT's Archives 12092811 for a summary of CBP's September ACEopedia).