CBP’s Centers of Excellence and Expertise (‘CEE’) continue to evolve and the Trade received an update during CBP’s recent Trade Symposium. Breakout sessions were held throughout the second day with representatives from all 10 CEE’s.
Following is a recap from CNI’s own Nic Adams, VP of Client Services, who was in attendance…
CBP is in the process of assigning importers to a CEE and expects to have all importers transitioned by the end of this fiscal year (September 30th.) Generally, the HTS numbers with the highest value determines which CEE an importer will be assigned to.
How can you determine which CEE you have been assigned to? The secret is to look at your Entry Summaries (CF 7501) and review the team number that has been assigned to the entry. Specifically, the 3rd digit of the team number determines the CEE. For example, if the 3rd digit consistently ends in ‘4’ then you, most likely, have been assigned to the Apparel, Footwear & Textiles. If the 3rd digit is not consistently the same number then you have not yet been assigned to a Center and your entry summaries are still being reviewed by the teams within your port of entry.
A list of all the teams within each CEE can be found online here.
CBP explained that you can appeal to them if you don’t believe your company has been assigned the most appropriate Center. For example, if you import parts to manufacture an electronic device you may be assigned to the Base Metals CEE and it may be more appropriate for you to be associated with the Electronics CEE.
Within each Center there are three distinct areas; Partnership, Compliance and Validations, and Enforcement. All three areas are learning more about their respective industries. This is accomplished by reviewing entries, supporting documents, and even meeting with importers to better understand their industry. This helps CBP to better identify anomalies and possible entry errors.
The Partnership team is involved with importers which are participating in Trusted Trader programs such as the Importer Self-Assessment or C-TPAT. Those importers are assigned an Account Manager within that Center and it was noted that National Account Managers (‘NAM’) are being transitioned the Centers in addition to importers. It may be that if you already have a NAM that you will receive a new Account Manager if your NAM is not associated with your Center.
The Compliance & Validations team is reviewing entries, issuing Requests for Information (CF 28), and taking other steps to ensure that an importer’s entries are compliant with Customs’ regulations.
Enforcement is, obviously, following up on violations and assessing penalties when appropriate. They are also reviewing allegations of entry violations by parties that feel they may be at a competitive disadvantage due to improper filings. Many of these allegations involve potential AD/CVD violations and the Centers are working with the Commerce Department so that scope rulings are clearer and it is easier to determine if a product is within the scope of the order.