CustomsNow recently attended and exhibited at the 2012 International Compliance Professionals Association (ICPA) conference in Atlanta. As usual, there was a terrific exchange of information among the attendees. Some key takeaways were:
Customs’ new system for the filing of entries, ACE, is on a fast track and CBP anticipates completely turning off the legacy system (ACS) in approximately 2 years. Before then, certain functionality within ACS will be turned off if no longer necessary. For instance, when the transition of Rail and Sea e-Manifest filings to ACE is completed by October of this year, AMS will be decommissioned in the Automated Commercial System (ACS).
Cindy Allen, who heads up the ACE project for Customs, explained that CBP is already working in ACE and it is their “system of record.” Even if you’re filing in ACS today, your entry summary data is transferred to ACE for processing by CBP. Cindy strongly encouraged brokers and self-filers to transition to ACE as soon as possible. Her favorite quote on this topic is “I’d rather be on the bus and not under it.”
This simplified entry pilot process is a game-changer and makes a lot of sense. Entry filers will be able to file their entries as soon as the bill of lading information is available and CBP will make their admissibility decision. (Currently they will only provide a release notification 5 days before ETA.)
While your shipment is en-route, you will be able to work with CBP or any Other Government Agencies (OGA) to resolve any issues or concerns they may have (Often the only “issue” is just that that CBP or an OGA must verify that the importer has the necessary permit/document that is required for importing their product) and obtain a full release before the cargo arrives in the US. This will provide more predictability and lead to less delays at the port. Simplified entry may eventually allow for the entry summary information to be filed on an aggregate basis, perhaps once a month.
There was a presentation on direct filing entries versus using a broker. The pros and cons for each option were discussed in a fair and balanced way. In the end, the consensus seemed to be that direct filing is a compelling option, due to the savings and increased control that accrue to the importer, if the importers has a solid understanding of the entry process. Importers of complicated products (special trade programs, FDA-regulated, etc.) that are interested in direct filing should consider hiring at least one individual familiar with the entry process who can then document and train the entire department. In addition, self-filing entries remotely brings greater uniformity to the process and reduces the need for port-specific entry knowledge.
Thanks to all who stopped by our booth. We enjoyed meeting you and hearing your ideas.