NCBFAA Urges CBP to 'Embrace' Electronic Data Submission Instead of Modifying Form 7501
The National Customs Brokers & Forwarders Association of America is urging CBP to "embrace" electronic data submission methods instead of proposing to modify paper-based Form 7501 to allow for situations where there are multiple countries of melt and pour or smelt and cast.
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Opting to focus on electronic data submission methods instead of modifying Form 7501 aligns with automation goals and minimizes data duplication, the trade association told CBP in response to the agency's call for comments on its planned modifications to Form 7501 (see 2511300002).
"The unnecessary duplication of data both in electronic format and through paper-based processes increases resource consumption for both the trade and CBP," NCBFAA said. "Moreover, it is worth noting that in cases where non-ABI transactions occur, CBP already possesses the necessary data from the paper documents that accompany the entry."
CBP had informed the Office of Management and Budget in December that it is planning to revise instructions for Form 7501, which is used for entry summary filing, to clarify what defines country of melt and pour for steel imports and what defines country of smelted and cast for aluminum imports.
But NCBFAA argued that the proposed requirements include data elements already being provided in ACE and that the printed 7501 form is only required for very limited scenarios, such as non-automated entries or warehouse entries or withdrawals.
"To make changes to the printed form is a burden to the trade to reprogram the form for a document that is not required for most entries. This proposed collection of information on a paper form is not necessary for the proper performance of the functions of the agency as the information is electronically available to the agency," NCBFAA said.
The trade association also said CBP's proposed changes refer to the paper version of Form 7501, which is an "archaic" approach and "hinders the efficiency of importation processes. Instead, we urge CBP to continue to embrace modern technology and fully transition to electronic submission methods. This transition would significantly reduce paperwork burdens and enable faster and more accurate data exchange between importers and CBP."
NCBFAA also noted that the proposed modifications to Block 22 don't account for multiple primary countries of smelt as they do for Blocks 21, 23 and 24.
Instead of modifying Form 7501, CBP should instead implement a change in the Customs and Trade Automated Interface Requirements (CATAIR) to establish electronic data transmission channels, which NCBFAA said would ensure that all CBP officers have access to comprehensive information through ACE.
"By relying on electronic data, the need to modify the paper Form 7501 would be obviated, as all relevant information would be readily available through existing electronic platforms. This suggestion enhances the quality, utility and clarity of the information collected as it remains in its electronic state and uses an appropriate automated and technological collection of information," NCBFAA said.