Before entries were being filed through ACE, the trade would file qualifying de minimis corrections via quarterly reports directly with various ports. Now, however, these corrections may be filed with a PSC via ACE.
Some in the trade are uncertain as to whether they should file a de minimis correction for both shortages and overages. CustomsNow™ recommends that that all the de minimis rule be followed for both. This opinion is based on the following excerpts from the ACE Entry Summary Business Rules and Process document (emphasis added):
- 16.1.1 PSC replaces post-entry amendments (PEAs) for all ACE entry summaries, with the exceptions noted below. PSC is a means for the importer to make electronic corrections via ABI on entry summary data presented to and accepted by CBP. Each PSC will be a full replacement of the entry summary data, and CBP will consider the PSC to be the importer’s “assertion” that the most recent entry summary data is correct.
- 16.2.14 CBP generally does not process refunds or bills under $20. However, the importer may request a refund for less than $20 via PSC functionality using the accelerated liquidation request indicator.
- When the PSC is received, CBP will perform a review, if required, and CBP will liquidate the entry using the two-week liquidation cycle
CustomsNow™ interprets this to mean that you should always make a correction, if eligible, no matter what the issue (overage, shortage, etc.) and that, if it falls under the de minimis amount of $20, you should not expect a bill or refund unless you specifically ask for it using the accelerated liquidation process.
However, check with your legal counsel to be certain that this is appropriate for your situation.