In response to comments from the trade, US Customs is modifying its Entry Summary, Accounts and Revenue (ESAR IV) test program for processing post-summary corrections (PSCs) via ACE. Among the changes, effective on December 19, 2013, are the following:
- The original entry summary filer, and any subsequent PSC filer, will have full access, via ACE reporting, to all entry summary data contained in any subsequent PSC filed (even if more than one PSC is filed for a particular entry). CBP will notify these parties when the first or any subsequent PSC is filed.
- These data elements will be added to those fields that cannot be changed via PSC:
- Date of Entry
- Surety Code
- Filing rule changes:
- A PSC cannot be made:
- On entries that have been protested
- When any merchandise covered by the original entry has been conditionally released and its right to admission has not been determined
- If filing the PSC will result in 1) the original entry (type 01) being changed to AD/CVD entry (type 03), or 2) a AD/CVD entry that results in additional AD/CVD duties due, the importer of record must deposit the associated AD/CVD duties when the PSC is filed.
- The original bond and surety remain on an entry for which a PSC is filed.
Comments concerning this notice should be submitted via email to Monica Crockett at ESARinfoinbox@dhs.gov. Please indicate “ESAR IV (Post-Summary Corrections Processing)” in the subject line of your email.
Since its post-9/11 inception, the US Customs C-TPAT program has helped the trade — and national security — by establishing a risk-based approach towards import cargo security. Many large US retailers are involved in the program, taking steps to ensure that their foreign suppliers pass muster. Recently, several large retailers have voluntarily joined forces to greatly improve the auditing of their suppliers’ factories. Their pilot program has met with great success, and they hope that other retailer join forces for a wider rollout.
According to an article in the November 2013 print edition of American Shipper, “Common security lens,” an unanticipated byproduct of the C-TPAT program has been “audit fatigue” — foreign contract manufacturers inundated with extensive audit requests from US retailers and their third-party auditors.
The result has been increased costs for suppliers to comply with these often duplicative audits, which require “managers to spend time answering questionnaires, preparing for on-site audits, accompanying audit teams during plant visits and paying for third-party auditors when retailers outsource verification.” Moreover, since the average factory is audited multiple times by different retailers annually, there is “confusion about whose standards to follow, inefficiency… and a focus on passing the audit rather than fixing any underlying problems.”
To address these issues, about 10 top US retailers — including Target, Home Depot and Levi Strauss — partnered to standardize audits in global supply chains. With input from US Customs and third-party auditors, they created a harmonized audit checklist that incorporates the eight major areas that CBP requires for C-TPAT certification, essentially “agreeing on minimum security requirements” while leaving the details of compliance up to each factory.
The advantages of a standard approach to security are numerous:
- Factories benefit by:
- having more clarity and consistency about requirements
- undergoing fewer audits, which enables them to focus on production and security.
- Retailers gain by:
- lowering costs of doing business
- focusing time and resources on corrective action, education and training
- exchanging best practices with other retailers and brands
After a successful pilot which resulted in some tweaking to the audit checklist, the working group of retailers hopes to broaden the program to include other retailers, by creating a website and LinkedIn group, and presenting at US Customs’ next C-TPAT conference.
US Customs has announced that its East Coast Trade Symposium, postponed last month due the federal government shutdown, will be held in the Washington, DC area on March 6-7, 2014. Details will be posted soon.
Effective November 4, 2013, US Customs has made changes to the Simplified Entry pilot program which launched in 2011:
- CBP has changed the name of the program to “ACE Cargo Release Test” to reflect the addition of enhance functionality for:
- automated corrections and cancellations
- split shipments
- in-bond cargo
- quantity less than full manifested bill quantity (if no in-bond)
- CBP has loosened the program’s eligibility so that direct filing importers and customs brokers no longer need to be participants in the C-TPAT program
- The program is now open to all eligible participants for an indefinite period, up from a 14-day period
- CBP has added 3 new data elements to be filed in ACE Cargo Release: Port of Entry, In-Bond (if applicable) and Bill Quantity