ACE: Complexities in shutting down ACS

US Customs is making great strides in rolling out ACE.  Entry filers already have the ability to file entry types 01, 03, and 11 in ACE, which represents over 95% of the entries filed annually.

Presently, however, the vast majority of entries continue to be filed in the legacy ACS system.  The entry summary information is then transferred to ACE which is “CBP’s system of record.”  Simultaneously maintaining two very large systems, and their databases, while attempting to keep then in sync, is very expensive for CBP and requires more programmers.

In order to reduce costs CBP is looking into requiring that entry types 01, 03, and 11 be filed in ACE.  Previously CBP’s position was that the compulsory filing of entries in ACE would not begin until ACE could handle all entry types.

One concern for the trade is the lack of entry edits in ACE today.  CBP plans to begin work on these edits in 2012 (see ACE Priorities and Work Plan document), but it is unclear if all of the edits in ACS will be replicated in ACE.  ABI vendors may need to update their systems to include the edits that CBP does not program into ACE.

Another worry is that current Remote Location Filing requirements do not allow for the filing of ADD/CVD (type 03) entries.  CBP has been encouraged to allow for the filing of type 03 entries remotely.

Finally, surety agents have expressed a concern about their ability to receive data on bonds they underwrite — and for the related entries filed under those bonds — from Customs through the Automated Surety Interface via ACS.  How will this work with ACE?

The Trade Support Network, an advisory board of trade representatives, provides guidance to Customs on ACE issues, including the decommissioning of ACS.   You can monitor their progress here.

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