Update on Post Summary Corrections (PSC) for importers

With the transition to ACE over the last few years, one of the big benefits was the improvement of the Post Summary Corrections(PSC) filing process.  With that, importers were looking forward to correcting entries quickly, easily, and less-expensively, regardless of the original filer.

However, last year, CustomsNow identified a bug in ACE which was preventing importers from filing a PSC for an entry that was originated by their 3rd party broker.  We worked closely with CBP to help resolve, and finally, we’re happy to announce that this issue was recently fixed. 

Now, many of our import clients are centralizing their correction process by either self-filing PSCs directly with Customs or by using CNI consulting to file on their behalf.  This is especially helpful to manage refunds for those lucky enough to have a China Section 301 Exclusion or other refund situation.

The process is simple; run an ACE report, make corrections to the data, upload using CNI’s Import Upload Tool, and transmit to CBP.  Results are returned in seconds and ACE data is updated immediately.  There is even an “Accelerated Liquidation Requested” box for refunds to request that the entry liquidate within the 2-week cycle.  Any follow up requests for documents from CBP are simply uploaded and transmitted via DIS.  Learn more here.

If you’d like to discuss, please contact us at sales@customsnow.com.

Sincerely,  CustomsNow™

Additional broker verifications on importers

According to this Federal Register notice, CBP is proposing amendments to the current broker verification regulations, and WOW!, it’s going to be a lot of additional work for the broker.  This proposed amendment will require customs brokers to collect certain information from importers to enable the broker to verify the identity of an importer. 

CBP believes this additional scrutiny will help to prevent fraud and impede the creation of shell companies by importers looking to evade CBP laws.

The following information is what CBP is suggesting, at minimum:

  1. The client’s name;
  2. For a client who is an individual, the client’s date of birth;
  3. For a client that is a partnership, corporation, or association, the grantor’s date of birth;
  4. For a client that is a partnership, corporation, or association, the client’s trade or fictitious names;
  5. The address of the client’s physical location (for a client that is a partnership, corporation, or association, the physical location would be the client’s headquarters) and telephone number;
  6. The client’s email address and business website;
  7. A copy of the grantor’s unexpired government-issued photo identification;
  8. The client’s Internal Revenue Service (IRS) number, employer identification number (EIN), or importer of record (IOR) number;
  9. The client’s publicly available business identification number (e.g., Data Universal Numbering System (DUNS) number, etc.);
  10. A recent credit report;
  11. A copy of the client’s business registration and license with state authorities; and
  12. The grantor’s authorization to execute power of attorney on behalf of the client.

The comment period is open to the public until October 15th, 2019 and may be submitted through the Federal eRulemaking Portal here.

CPSC begins to integrate with ACE

The September Trade Support Network (TSN) monthly meeting featured speakers from the Consumer Product Safety Commission (CPSC) and our own Nic Adams, VP Client Services for CustomsNow, was there. 

The CPSC representatives announced that in late Fall, 2019, they will be deploying functionality that will link their Risk Assessment Methodology system, known as ITDS/RAM, with ACE to further coordinate efforts with CBP and the trade community regarding examination and disposition results. This represents the culmination of 2 years of work with CBP to achieve the first phase, Hold Request and Conditional Release Coordination.

This first step in integrating with ACE will allow CPSC to more effectively notify CBP of shipments that are of concern and may require an examination in order to ensure the product is safe for consumers. (Today they manually notify CBP Officers of shipments they wish held.)  They explained there are over 300 HTS numbers that they have identified as high-risk.  The list of HTS numbers is not readily available but general product categories.   Learn more details about this new program here.  TSN members strongly suggested they work with CBP to flag those HTS numbers as other PGAs generally do. 

The CPSC uses the entry data primarily to identify high-risk shipments and, therefore, their review cannot begin until the entry is filed.  They will not receive the entry details from CBP until the entry has been filed and the conveyance has been ‘arrived’ by the carrier. 

Nic asked, “If a shipment is ‘Under Review’, should the filer upload the commercials to ACE’s Digital Imaging System (DIS) right away”?  The answer was “No”, and if the CPSC believes the commercial documents may be of value, they will contact the filer and request the documents. 

This process is like the one employed today by CBP-Agriculture, who do not receive PGA data from the filer.  Rather, they review manifests for products that may cause harm to U.S. agriculture.  Please see the CPSC Participation in 1USG Notification Messaging at Import, attached, for more. 

Contact CustomsNow if you have any questions @ sales@customsnow.com.