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ACE: CBP updates PGA Filing Status document

Tuesday, April 25th, 2017

US Customs has posted an updated version of the PGA Filing Status document.

The updated version includes the status of import and export PGA pilots, the accepted electronic filing methods, and indicates those PGAs that are no longer accepting paper filings. For reference, this document also contains the relevant PGA announcements in the Federal Register, as well as agency contacts for filing questions.

ACE PGA Filing Status Apr 2017 update (1)

 

Importers: This could be the cause of your FDA rejects

Monday, April 24th, 2017

From CSMS #17-000227:fda1

CBP and FDA are in the process of updating the ACE PGA flags for FDA requirements.  Specifically, the tariff numbers that had flags for ACS OGA of FD0 are getting ACE PGA requirements updates to have either no FDA flag, FD1 (FDA May Be Required) or FD2 (FDA Required).

In the meantime, following is a spreadsheet of the FDA HTS codes and their associated flags in ACE. Trade can use this as a reference in investigating any rejects they may be getting when filing entries. FD0 flags do not exist in ACE.

If you have questions about the HTS flags please contact FDAImportsInquiry@fda.hhs.gov or Ted.Poplawski@fda.hhs.gov

CBP spreadsheet >> FDA HTS codes and flags

 

 

 

 

 

Get the latest scoop on CBP’s Simplified Processes Initiative

Friday, March 31st, 2017

On March 24, the NCBFAA sponsored a webinar on the Simplified Processes Initiative, presented by Randy Mitchell, Director, Commercial Operations and Entry Division, US Customs Office of Trade Policy & Programs.  Here’s a summary:

In 2011, CBP launched the Simplified Processes Initiative, a collaborative effort to develop innovative solutions to critical issues emerging at the intersection of trade facilitation, enforcement, and national security.  An early success was the implementation of the Simplified Entry (Cargo Release) pilot aimed at simplifying the importation process.

CBP reengaged the Simplified Processes Initiative in 2014 to advance border security and management; enhance U.S. competitiveness by enabling lawful trade and travel; and promote organizational innovation.

A Simplified Processes Working Group was established to identify challenges and discuss potential solutions to critical trade needs; gather requirements; and develop a proposed alternative. To date the group has identified five post-release areas of opportunity:

Monthly Summaries and National Statements

  • Filers may submit a monthly summary that includes releases over a calendar months’ time.
  • Each line of a monthly summary is considered a “reconfigured entry” that is subject to liquidation, protest and any other downstream process.
  • A separate National Financial Monthly Statement will include debits (duties, taxes, fees, bills and interest) and credits (refunds) netted as a total balance due for a calendar month.

If an importer elected to participate they would receive only one statement per month covering all ports of entry and there would be no Daily Statements to approve.  Also, the statements could include both Debits and Credits.

Liquidation

  • Allow for deemed liquidation of all consumption entries at one (1) year from the date of entry.
  • Implement processes to accommodate line-level liquidation.
  • Allow for the importer to obtain liquidation status details from their ACE portal account or CBP.gov.

This will allow lines within an entry to liquidate without having to wait for lines subjected to AD/CVD case reviews to be resolved.  Also, it would benefit Drawback filings since they are also filed at the line-level.

Protest

  • Transition the protest process to an electronic format (this has already occurred and all Protests must now be filed in the ACE Portal.)
  • Expand the electronic protest filing to a broader range of trade stakeholders such as attorneys, importers, and sureties.
  • Auto-populate numerous Entry Summaries onto one protest while providing protest statuses on ACE.

Reconciliation

  • File all reconciliation data electronically and only with necessary data elements.
  • Eliminate the requirement of having to file an 09 entry and extend liquidation for flagged entries/lines an extra year from the date of entry.
  • Manage reconciliation by account and permit filing at any Center or POE.

The vision is that Reconciliation entries will be replaced with Post Summary Corrections.  One of the biggest benefits would be that the Trade would only need to provide the reconciled amounts and not the original amounts since ACE already knows the original amounts.  Also, if no PSC is made, it indicates no changes are needed on the reconciled entry and is then subjected to liquidation. Finally, the process would allow a filer to retroactively flag/un-flag an entry/line through a PCS in ACE up to the deemed liquidation date.

Drawback

  • Develop a process for the claimant to submit a “drawback profile” electronically along with automating other Drawback processes in ACE.
  • Track/validate if the bond coverage is sufficient prior to processing an Accelerated Payment requests.
  • Initiate the Desk Review and response processes electronically, to include DIS.

ACE controls will track and validate if the bond coverage is sufficient prior to processing an Accelerated Payment Request.  Drawback profiles will be submitted electronically using the 5106 form.

These process improvements are continuing to be reviewed and approved as necessary and are subject to budget approval.  Therefore, there is no firm date on when they will be rolled out.   Meanwhile, here’s the PowerPoint presentation from the webinar > Simplified Process Initiative_Webinar_March_2017

Screen Shot 2017-03-22 at 8.54.41 AM

 

ACE: New and updated PGA info posted on CBP.gov

Tuesday, March 14th, 2017

pgasseal_aceCBP has recently posted new and updated information on ACE and Partner Government Agencies on CBP.gov.

 

++++++++++

Also posted on CBP.gov:

FDA Webinar – January 31, 2017fda1
The purpose of this webinar was to review updates to FDA’s Supplemental Guidance for ACE Version 2.5 and the related PGA samples. FDA also addressed trade questions during the webinar.
Webinar Recording | Transcript | Presentation | Technical Guides

 

 

Even with ACE, importers still missing mission-critical line level part/SKU reporting

Tuesday, March 7th, 2017

Now that import entry processing has completely converted to ACE, reports in the ACE portal are rapidly replacing the traditional ITRAC reports as the source of ‘truth’ for entry information.  Finally, importers have access to the single source of data that CBP relies on, and data inconsistencies are a thing of the past (hopefully).

Unfortunately, though, most importers still struggle with obtaining entry level reporting that includes the importer’s Purchase Order and part/SKU numbers at the ENTRY LINE LEVEL.  Importers need this detailed level of reporting for many purposes, including:

  • Auditing their filings
  • Reviewing their overall import activity to find anomalies
  • Researching duty saving strategies
  • Preparing reconciliation entries
  • And more…

So, while ACE reports are somewhat helpful, they still do not provide enough granularity to be readily actionable by the importer.

One solution to this issue is self-filing.  When importers bring the filing process in-house and use data to automate the process, it’s easy to file at the part/SKU level.  CustomsNow™’s ABI system features a “Product List” (aka Parts File) which can capture ALL potential CBP declarations (e.g. HTS, FTA, ADD, Assist, etc.), as well as ALL required PGA information.

At the time of entry, users either select each part/SKU from the parts file or automatically upload an entry file, and all CBP and PGA data automatically populates the entry.  Entry is reviewed and transmitted to CBP, giving the importer line level visibility.  For non-self-filers, brokers will typically either consolidate some HTS lines to ease the data entry process, or will impose heavy charges to the importer for “additional entry lines.”  Not so with self-filing.

Filing at the part/SKU line level not only leads to increased productivity and compliance, but allows for detailed reporting on demand. Some of the most popular reports used by CustomsNow™ clients are:

  • Entries by Product – Isolates all entries and entry data for a given product or SKU, giving importers the ability to report on anything (duties, taxes, release time, SPIs, etc.) at that level.  Critical detail necessary for post entry work, such as protests, prior disclosures or reconciliation.
  • Duty Allocation Report – Allows the importer’s accounting department to easily allocate duty, taxes, and fees to specific P.O.s.  Both Daily and/or Periodic Statements can be ‘broken down’ to this level for accounting purposes.
  • Daily Status Report – Provides an overall view of all active entries, including CBP status messages.  Sorting on the ETA quickly identifies shipments which have arrived but not have cleared CBP and/or a PGA.  It includes a myriad of information (ie: container, BOL, and PO numbers, etc.) so that the reviewing party can quickly isolate shipments which may be of concern.

Please contact us if you would like to learn more about our Parts File/Products List, or any of our other ABI solutions.

partsfile-03

 

ACE implementation winding down

Friday, February 24th, 2017

seal_ace

After several tumultuous years there is finally a light at the end of the ACE tunnel.  The next significant release falls into the “Post Release” bucket and covers drawback, liquidations, duty deferral, reconciliation, eBond, as well as a few more housekeeping measures.  This release, originally scheduled for January 14, 2017, was postponed in order to provide the trade with more time to code and test the changes.  CBP has not announced a deployment date.

Beyond these updates, the ACE Deployment Schedule lists only “TBD: Mandatory use of ACE for electronic filing of remaining PGA data, pending PGA regulatory updates” as outstanding work to be done.

Many in the trade are enjoying the respite from the barrage of changing functionality and requirements and looking forward to stabilizing their import programs while enjoying the benefits of ACE (ie: Post Summary Corrections, ACE Portal Reporting, etc.)

At CustomsNow™, our programmers, after some well-deserved down time, have returned to upgrading the functionality within our systems and we’re very excited about some of the coming enhancements including web-based functionality, the ability access our applications using phones and tablets, and much, much more.

FDA entry reject? Could be a food facility registration issue…

Wednesday, February 15th, 2017

rejected

If your entry was subject to an FDA reject, perhaps the food facility involved was not properly registered.

Per CSMS #17-000078:

FDA invalidated food facility registrations that failed to renew during the 2016 biennial registration period. In addition, food facility registration were invalidated for failure of confirmation by a US Agent and/or foreign manufacturer (registered by a third party) as required under the FDA Food Safety Modernization Act (FSMA), Section 415 of the Federal Food, Drug, and Cosmetics Act (FD&C Act) [21 U.S.C. § 350D] and in accordance with 21 CFR 1.231(a)(5) and (b)(7). (Please see related CSMS message 16-001052). [And see our related blog post]

  • If you are receiving an entry rejection for an invalid registration, you will need to confirm the status of the registration with the manufacturer. The manufacturer may check the status of their registration by logging into their FURLS Food Facility Registration Module account to verify the status of the individual registration.
  • Registrations that have been invalidated cannot be renewed and a new registration will have to be created. The US Agent or the owner must confirm the receipt of the registration within 30 days for it to be valid in the FDA reference database.
  • Failure to have a valid registered manufacturer can cause a shipment delay greater than 24 hours, therefore it is not recommended to file a prior notice if the registration is pending or use a facility registration that was invalidated due to failure to renew or confirmed by the US Agent/Owner.

ACE information: For this reject the sub-reason code 112 is sent back in the SO transaction for entries, SO71 record. For Stand-Alone prior notice filings, in the PO transaction the code 112 is in the PO71 record.

  • Contact FURLS Registration Help Desk at FURLS@fda.gov or 800-216-7331 to verify the current status of the your Food Facility Registration. Please expect long wait times for phone calls.
  • Contact FDA ACE Support 24/7 at ACE_Support@fda.hhs.gov or 877-345-1101 for ACE inquiries to determine the rejection reason.
  • Contact Division of Food Defense Targeting at prior.notice@fda.hhs.gov or 866-521-2297 for assistance with valid food registrations verified by FURLS Registration Desk that may be rejecting improperly.

Three new FDA import updates

Friday, February 10th, 2017

FDA has been and continues to be a very active PGA when it comes to ACE matters:fda1

 

1.  Submission of FDA data in ACE

As discussed in a previous blog post, CBP and FDA are working to implement changes related to FDA’s Final Rule on Submission of Food and Drug Administration Import Data in ACE  and corresponding Supplemental Guide. The first deployment occurred on January 5, 2017, and a second is to occur today.

2.  Common FDA rejects in ACE
In an effort to keep the trade community aware of how ACE is progressing for FDA transmissions, FDA has identified the most common FDA (bucket 2) rejects.• Invalid Product Code• Invalid Food Facility Registration Number• Mismatch between Food Facility Registration and Manufacturer

• Invalid state/zip code combination

• Foreign Consignee

• Duplicate Entry

• Missing or incomplete entity address

For specific information related to the various FDA error codes, please refer to FDA’s Error Guide.

3.  FDA Requirements Change for Medical Devices, IUC 081.005

The requirements for transmitting medical device constituent parts for drug-device IND combination products, Intended Use Code 081.005 have been changed.

The following Affirmations of Compliance for IUC 081.005 are now conditional: DEV, DFE, LST. These Affirmations of Compliance are in addition to DA and IND, which are already indicated as conditional. This change will be reflected in the next version of FDA’s Supplemental Guide

 

For questions on any of the foregoing, contact FDA ACE Support

ACE_Support@fda.hhs.gov or 877-345-1101 or 571-620-7320

ATF imports? Big change for submission of PGA information

Monday, February 6th, 2017

atf-logo

 

From CSMS #17-000056:

Effective immediately, importers filing ATF information electronically through ACE are required to use the PGA Message Set. DIS images of ATF Forms, including Form 6 and 6A, will no longer be accepted. When the PGA message set is filed correctly, the importer will received an automatic “May Proceed” from ATF, and if there are no further issues, the shipment will be released. Please note, original paper ATF Forms 6 and 6A may also be submitted to the ports of entry. For further information about PGA forms and filing procedures, visit CBP’s webpage on this topic.

ACE: Free FDA webinar 1/31 to review Supplemental Guide 2.5

Thursday, January 26th, 2017

fda1

 

FDA and CBP will be hosting a webinar on Tuesday, January 31, 2017 from 1:00 pm – 3:00 pm Eastern Time to review updates to FDA’s Supplemental Guidance for ACE Version 2.5 and the related PGA Samples.  FDA will go over updates to the Implementation Guide that will go into Production on Thursday, February 9, 2017.  FDA will also address the trade’s questions during the webinar.

registernow

 

(Note: Registrants will also be able to submit questions in advance via the registration link.)