As anticipated, US Customs has extended by four months the time by which importers must file all electronic entries and entry summaries in ACE. Note, however, that CBP has emphasized that the originally published deadline for the complete cut-over to ACE from ACS is holding fast: “We would like to reiterate that the [extended] transition period does not impact our December 2016 deadline for full implementation of the Single Window via ACE.”
From CSMS #15-000664:
Nov 1, 2015: Beginning of a transition period for electronic entry and entry summary filings in ACE to allow industry and participating government agencies more time to test and provide feedback as they fully transition into the new system. Use of ACE is allowed and encouraged for electronic entry and corresponding entry summary filings for entry types 01, 03, 11, 51, and 52 with or without PGA data.
Feb 28, 2016: At this time, filers will only be permitted to file in ACE, and no longer permitted to file in ACS, all electronic entries and entry summaries. In addition, electronic FDA, NHTSA, and APHIS (Lacey) data must be filed in ACE, and ACS will no longer be available.
July 2016: Upon publication of the Final Rule, ACE must be used for filing AMS, APHIS Core, ATF, CDC, DCMA, DDTC, DEA E&C, EPA, FSIS, FWS*, NMFS and TTB data. Hybrid submissions will no longer be allowed.* This requirement for FWS is contingent on FWS having its regulatory revisions in place by the July 2016 publication of the CBP Final Rule eliminating hybrid filings.
The International Trade Data System (ITDS) Committee of the Trade Support Network (TSN), an advisory board of trade representatives that provides guidance to US Customs on ACE issues, is seeking members of the trade to form a working group to discuss a technical solution to be used by the US Consumer Product Safety Commission in the pilot to test the new cargo release and control functionality of ACE/ITDS.
You must apply by this Friday, September 4. See CSMS #15-000642 for details.
Per US Customs’ CSMS #15-000623:
Last week, [CBP] initiated the first Phase (I) of the PGA Pilots. [FDA] and [NHTSA] entry data transactions were successfully transmitted, accepted and processed in [ACE]. The second Phase (II) of the PGA Pilots is scheduled to begin on September 2, 2015, with an expansion to additional ports.
In advance of the November 1, 2015 ACE mandatory filing date, CBP has also published a comprehensive overview of the schedule of PGAs and ports participating in the PGA Pilot.
In our experience, CustomsNow™ has seen importers who are participating in CBP’s Centers of Excellence and Expertise (CEE) program have quite a positive experience. Primarily, the program provides these importers with the opportunity to educate the CEE staff regarding their businesses, reducing the need for separate and often duplicate port requests, slowing cargo. Moreover, the CEE staff has been doing a remarkable job advocating on the importers’ behalf in certain situations. For example, the issuance of CF28s are no longer duplicated at the port level. In addition, the CEEs can assist with the reduction of redundant cargo exams at the port of entry.
The CEEs seem to be living up to their goal that “[t]he Centers were established to increase uniformity of practices across ports of entry, facilitate the timely resolution of trade compliance issues nationwide, and further strengthen critical agency knowledge on key industry practices.”
The only slight downside, according to some importers, is that the volume of requests for electronic invoices (AIIs) at the entry summary level tends to increase, at least initially. It appears that the Centers works hard to learn the nuances of the importers business transactions, then, over time the AII requests lessen, leaving the CEE in a good position to provide that tailored support. So a little extra time invested by the importer up front can significantly payoff down the road.
Following are the high level results of US Customs’ January/February 2015 survey of the trade on satisfaction with ACE in calendar year 2014. There were about 200 respondents, of which 93% were ACE users.
- Based on the 1-year and 4-year trends, trade user satisfaction rates increased and dissatisfaction rates decreased
- For ACE features deployed through Deployment A – D, trade users were most satisfied with entry summary features and least satisfied with PGA related processes
- Trade users were satisfied with their assigned client representatives: 73% Satisfied / 16% Neutral / 11% Dissatisfied
- Trade users were quite aware of the November 1, 2015 mandatory use date: 91%
- Among all trade respondents, Brokers/Self Filers anticipate filing 100% of their Entry/ES before Nov. 1, 2015 as below:
- Before Jul. 4, 2015 – 36%
- Jul. 4 – Oct. 1, 2015 – 32%
- Oct. 1 – Nov. 1, 2015 – 32%
CBP also identified 22 new trade users’ requirements, based on the following respondents’ concerns:
- Ease of use
- System functionality
- General ACE system
Back in January 2014, as reported in this blog, US Customs instructed the trade to not to use a Post-Summary Correction (PSC) (or Post Entry Amendments (PEA)) filing to submit invoices that were omitted from an entry filing. Rather, filers were directed to file a new entry with the missing invoice(s).
Now, however, CBP has reversed course as ACE gets closer to serving as the agency’s official system of record for trade transactions. In CSMS 15-000521, has advised that omitted invoices are now permitted for submission on both PSCs and PEAs.
US Customs has updated the ACE Entry Summary Business Rules and Process Document accordingly.
The Entry Committee of the Trade Support Network (TSN), an advisory board of trade representatives that provides guidance to US Customs on ACE issues, is seeking members of the trade for help in working through matters on forthcoming ACE functionality. Specifically, the organization:
“…would like to establish Trade Working Groups to discuss upcoming requirements and capabilities for Post Release functionality development that began in Increment 10 and will extend to future Increments. Specifically, we are looking for trade volunteers to participate in the following three working groups:
In order to make these discussions manageable and productive, we would like no more than 10 trade members per working group (members can sign up for multiple working groups).
Once the working group members have been identified, we are targeting scheduling several on site sessions [in Washington, DC], beginning the week of August 17th or August 24th. Your input on which week is preferable would be appreciated. Each group will have one full day to meet with the ESAR Team (either Monday or Tuesday or Wednesday). Once we hold our first meeting, we will determine whether additional on-site meetings or teleconferences will be required.”
If you’re qualified and interested, please contact Amy Magnus [firstname.lastname@example.org] and Lee Sandler [LSandler@strtrade.com] with Working Group preference and availability for meetings week/day of August 17th and week/day of August 24th.
The TSN provides a forum for the discussion of significant modernization and automation efforts with the trade community. There are approximately 300 members of the TSN that represent the entire breadth of the trade community, including trade associations, importers, exporters, brokers, carriers, sureties and others.