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RLF not always paperless

Pursuant to US Customs’ Remote Location Filing (RLF) rules, customs brokers with a national permit may file entries electronically in any RLF-operational port, even from a location other than where the goods are being entered.

While the RLF program is intended to be a completely electronic, paperless process, there is a little known rule — the hybrid policy — which provides for CBP review of certain other government agency (OGA) paper forms in conjunction with the the RLF data filed electronically in ACS or ACE.

Specifics about the hybrid process, including the situations where it would apply, the port at which paper documents must be filed (port of entry) and other requirements (e.g., original document vs. fax), are available in CSMS #11-000178.

Self-filing importers may file electronically in any port, subject to ABI filing requirements.  In our opinion, this hybrid policy should apply to filings made by direct filers via the Electronic Invoice Program (EIP), as CBP treats the RLF and EIP programs as the same.

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