While the NCBFAA favors pushing out the date for ACE crossover due to serious concerns about its functionality, the organization understands the political realities surrounding ACE, and advises the trade to be ready February 28 migration. Following is a letter to NCBFAA’s membership from its president, Geoffrey Powell:
I wanted to update our membership on what the NCBFAA has been working on in regards to the February 28 mandatory ACE migration.
A number of NCBFAA officers, committee chairs and counsel have been meeting multiple times per week with all the federal agencies to discuss ACE and Single Window. Right now ACE will be mandatory on February 28. As we have stated in the past, and continue to stress, everyone needs to be on ACE. We do not believe that the February 28 mandated ACE use will be pushed back. However, we are unsure at this time that all functionality will be required on February 28 and whether ACS will be turned off at that time.
For those companies that are not on ACE, and where ACS has been decommissioned, the only alternative to file entries is with paper documents, which guarantees longer the processing time for anyone filing in a paper environment. In February 2014, President Obama signed Executive Order 13659 requiring that 47 government agencies be on the Single Window by December 31, 2016. A timeline for the remainder of the year has been constructed to on-board all these agencies to ensure this Executive Order is met before the end of the current administration, therefore there is great political pressure being applied to ensure success.
The first critical milestone to be met is the movement of entries from ACS to ACE, and to file all FDA, NHTSA and APHIS (Lacey) by February 28. It is the NCBFAA’s belief that the White House will not accept pushing back the February 28 date due to the impact it will have on the remaining requirements to achieve Single Window by December 31, 2016. The NCBFAA will continue to meet not only with the Federal Agencies involved in Single Window to ensure a successful migration on February 28th, in what form that will take is still under discussion, but will also continue to keep Congress apprised to ensure the impact on trade is not catastrophic.
Click on this link to review a February 2 letter the NCBFAA submitted to CBP on our recommendations for February 28. As we wait to hear what is decided, I can only stress that ACE migration is here and each company needs to be using ACE now.