Too many Post-Entry Amendments (PEAs)?

Some US importers are concerned that if they file “too many” PEAs, they will draw increased scrutiny of CBP, and may be setting themselves up for an audit.  Though that may be the case, importers can and should take steps to minimize, regardless.  Obviously, in order to reduce the number of PEAs filed, it behooves the importer to minimize data errors before the entry summary is filed.  To that end, following are a few suggestions:

  • Have a written procedure manual in place that outlines the responsibilities of internal staff and broker(s) for reviewing entries and supporting documentation prior to submission.
  • Involve and have written agreements in place with vendors, suppliers, forwarders, etc. that specify steps to be taken to ensure data accuracy.
  • Mandate training for all involved parties if the same errors persist.
  • Automate the audit process.  For example, request that your broker send you a file representing the entry details and systematically validate the HTS, value, etc.
  • If most of your errors are for one issue (e.g., HTS), consider flagging the entries for reconciliation.

An inordinate number of PEAs may trigger increased CBP scrutiny, specifically by the Import Specialist(s) in the port(s) where submitted.  If this is a concern, make sure to communicate to the IS the reason for the influx, and the specific plans in place to minimize errors going forward.

As many know, the PEA process is cumbersome, laden with paperwork, and inconsistently administered by the ports.  To avoid these pitfalls, consider filing entry summaries in ACE instead of ACS.    By doing so, you can bypass the PEA process and avail yourself of the Post-Summary Correction (PSC) process, which not only is paperless (electronic) but allows importers to file corrections up to 270 days after the date of the entry (currently 10 days if filing in ACS).

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