CBP to terminate courtesy paper notice of liquidation program – what is your plan?

As of September 30, 2011, US Customs will terminate its policy of sending paper courtesy notices of liquidation to importers.   For some importers, this is the only direct notice, albeit informal, that they have regarding the status of an entry’s liquidation.   Despite this turn of events, importers who rely on the paper notices have several options of which they can avail themselves to continue to have visibility to entry liquidation.

Currently, CBP issues electronic courtesy notices of liquidation to all ABI filers: importers of record who file their own entries and customs brokers who file as the duly authorized agents of the importer of record. CBP also mails paper courtesy notices to all importers of record whose entry summaries are scheduled to liquidate by each port of entry.

This renders duplicative the paper courtesy notice sent by CBP to importers of record that file their own entries in ABI because, as an ABI filer, they already receive an electronic courtesy notice.

To save $3,000,000 in postage annually, Customs is discontinuing the paper courtesy notices.  Therefore, as of September 30, 2011, there will be 3 distinct groups of entry filers whose liquidation notice status is as follows:

  1. Importers of record who direct file their own entry summaries in ABI will receive only the electronic courtesy copy.
  2. Customs brokers who file on behalf of importers via ABI will receive only the electronic courtesy copy.
  3. Importers of record who file a paper formal entry with Customs will continue to receive the paper courtesy copy.

Importers in group 1 will not be affected by the discontinuation of the paper courtesy notices, as they will continue to receive an electronic copy of the liquidation notice.  Similarly, importers in group 3 will be unaffected, as they will still­­­­­­­­­­­­­ have direct visibility to the paper notice of liquidation status.  In addition, importers in either group who have an ACE account can monitor liquidation in that system.

Unfortunately, importers who hire customs brokers in group 2 to file their entry summaries via ABI will no longer receive a paper courtesy notice.   Without that notice, these importers will not have any direct visibility to whether and when an entry has been liquidated.  Nevertheless, an importer in this category has options:

  1. Request a copy of the liquidation notice from the customs broker, who is required by law to provide this information. However, there is no guarantee that the broker will comply with this request in a timely manner.
  2. Request that the broker provide access to the broker’s ACE Portal Account to monitor liquidation status of entries filed by the broker. Unfortunately, some brokers may be unwilling or unable to grant this request
  3. Set up its own ACE Portal Account to monitor entry filings made using the importer’s IOR number. This option is not currently available. Customs claims that ACE is being reprogrammed to allow importers of record to do so, by the effective date of the termination of paper courtesy notices (September 30, 2011).  Given CBP’s spotty record in launching timely, fully functioning updates to ACE, importers who wish to pursue this option should be cautious.  In addition, the ACE Portal contains entry data for the past 4 fiscal years, so this option will be of no help to importers who need information about entries filed before then.
  4. Direct file its own customs entries with an ABI-approved system to gain direct visibility and immediate notice of all liquidations. Since doing so will give the importer complete control, the importer will not have to rely on the whims of a broker providing the notice or granting the importer access to the broker’s ACE Portal Account.  In addition, the importer will be not be dependent on whether the aforementioned ACE functionality will be ready and fully functional by the stated deadline.  Finally, the importer that self files will have access to liquidation status of all entries it has filed, not just those in the past 4 years.

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