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Say “Goodbye” to blanket flagging in Reconciliation on July 8th, 2017

Friday, June 9th, 2017



It’s the same story we posted on January 10th, 2017, only this time it’s actually going to happen.


As a follow up to yesterday’s blog, CBP pulled out a bit of a surprise this week in announcing that reconciliation was finally moving to ACE, along with other Post Summary capabilities, effective July 8th, 2017.

With this deployment, US Customs will no longer apply ‘Blanket Reconciliation Flagging’ to entry summaries.  CBP has left it up to the importers and their brokers.  As a result, all reconciliation flagging must be done on an entry-by-entry basis.  Read the June 8, 2017 CSMS & Federal Register notice.

Importers that currently benefit from blanket flagging on their recon entries should work with their customs brokers to ensure entries are flagged in accordance with the importer’s requirements.  If self-filing*, importers should ensure that their ABI software providers’ systems are programmed accordingly.

Failure to properly flag entries for reconciliation, will require importers to submit 520(d)s, post-summary corrections or prior disclosures to correct issues that are otherwise handled by reconciliation, depending on the specific situation.

On yesterday’s ACE technical call, we were told that flags can only be added retroactively by sending a request to CBP HQ, however, we have yet to see a detailed explanation of the process.

By way of background, CBP announced in the December 12, 2016, Federal Register that:

  • CBP is streamlining the process for blanket flagging underlying entries for reconciliation.
  • Under the existing process, importers provided CBP a request asking that CBP input and apply a blanket flag to all underlying entries filed by the importer for a specific time period. Importers also identified the specific issue(s) for which they requested that CBP input and apply the requested blanket flag.
  • This document announces that effective January 14, 2017, importers no longer will submit requests asking that CBP apply a blanket flag on their behalf. Instead, importers may input and apply a blanket flag themselves. Importers who use blanket flagging must continue to identify the issue(s) they are flagging.

Please note that reconciliation flags are applicable ONLY to entry summary types 01, 02 and 06

 * CustomsNow™ self-filing clients have the ability to manage their recon flags at either the “blanket” level, or even at the Part/SKU level, a fantastic option. Learn more.

ACE Post Release Deployment – Hot off the press and one month to prepare!

Thursday, June 8th, 2017


On June 8, 2017, CBP issued CSMS# 17-000334 – ACE Post Release Deployment, and published a Federal Register notice announcing the implementation of a series of new Automated Commercial Environment (ACE) capabilities effective July 8, 2017.  These capabilities include Collections and Statements, Reconciliation, Drawback*, Duty Deferral and Liquidation.

A little history…  On December 12, 2016, U.S. Customs and Border Protection (CBP) published notices announcing that this functionality would be deployed in ACE on January 14, 2017. The Trade expressed concern that this did not allow enough time for coding and testing.  On January 17, 2017, CBP published a notice in the Federal Register announcing that the effective date for the test modifications would be “delayed indefinitely”, with rumors of late 2017.

However, in TODAY’s Federal Register notice, CBP states that they have “assessed stakeholder readiness for the mandatory transition of post-release capabilities in ACE” and that they, and the Trade, are comfortable with moving forward on July 8th, 2017.

Ready or not, here it comes!  The most critical aspect of this deployment is that blanket flagging for reconciliation will no longer be in effect starting July 8, 2017.  More to follow from CNI on this topic.

Questions related to the Federal Register notice may be emailed to CBP at

*Drawback capabilities – Please note that the drawback capabilities being deployed on July 8, 2017 are part of the ACE core trade processing capabilities, and include the following: 

• Consolidation to single entry type 47
• For electronic claims, submission of entire drawback package electronically
• System validations
• Integration with post release processes
• Improved system controls


CBP clears up guidance for air split shipments

Thursday, May 18th, 2017


In CSMS #17-000279, US Customs has clarified the process for air split shipments:h

  • CBP regulations require that all cargo arriving on split conveyances be entered in the air manifest system. The carrier is required to manifest the air waybill, in accordance with the CAMIR, as a split with the data for each conveyance and any in-bond transaction to move the cargo to the same entry port.
  • Cargo moving on the same air waybill but not declared in the ACE air manifest system as a split, is not eligible for split entry processing. As such, one entry per conveyance is required. This applies to a single house air waybill split across multiple master air waybills.
  • ACE currently does not have an edit to enforce this policy. ABI filers can determine if a carrier’s air waybill was split by submitting a cargo manifest entry release query (CQ transaction). Split air waybills will have a part indicator A, B, C, etc. in the response message.
  • It is the filer’s responsibility to ensure that cargo on a single bill of lading, moving on multiple conveyances, and not declared as a split are entered separately.

Importer’s lament: “Why isn’t my release visible to my carrier?”

Friday, May 12th, 2017


Nic Adams

Nic Adams

Nic Adams, CustomsNow’s Vice President, Client Services, offers guidance for importers who are frustrated that their carriers don’t seem to have visibility to shipment releases even when there is a CBP release on the cargo:

I have a Customs release, and a 1USG, but my carrier says my shipment isn’t clear.  I know I referenced the correct I.T. and Bill of Lading numbers on my entry (I didn’t receive any responses from CBP indicating a No Bill Match.)  Why isn’t my release visible to my carrier?

We often receive this question from our clients.  Invariably, it involves a shipment that is moving In-Bond via truck or rail.

After receiving the Arrival Notice with the I.T. information, the client enters the appropriate information into our ABI system and transmit the entry to CBP.  Normally the cargo responses come back in this order:

  • SE DATA ACCEPTED  (SE=Simplified Entry)
  • RELEASED (along with a Release Date which is the expected ETA at the inland port)
  • DATA UNDER PGA REVIEW (for shipments subject to a PGA such as FDA)
  • MAY PROCEED (along with a ONE USG meaning the shipment has cleared CBP and any/all relevant PGA’s)

At this point, most our clients will then query the bill of lading in the Automated Manifest System to ensure the release has posted to the bill of lading and that, therefore, the carrier has visibility to the release (a release is posted against a bill of lading in AMS with a code of ‘1C’).

But, no release has been posted.  Why is that?  The reason is that CBP posts releases to the carrier’s manifests based on different factors.  These rules can be found on page 17 of US Customs’ ACE Cargo Release Business Process document:

CBP sends a notification of release to the filer, carrier, and the terminal facility/custodian as appropriate… That information is sent at different times for different modes of transportation.

  • Land Border (Truck and Rail) – at time of arrival (may be sent earlier in rail depending on location)
  • Ocean – as early as 5 days prior to the estimated date of arrival
  • Air – as early as 4 hours prior to the estimated date of arrival

The key for truck and rail shipments is that the shipment must be arrived… not just physically arrived but deemed “arrived” in AMS.  This means that the In-Bond status must be updated from ER (en route) to AR (arrived.)  Then, and only then, will the 1C be posted to the bill of lading.  It is not uncommon that carriers do not ‘arrive’ their In-Bonds timely and, in this case, we advise our clients to contact the carrier and request that they arrive the In-Bond so the customs release can post.

Please contact Nic if you would like to discuss this topic in more depth.





ACE Portal: Updated CBP guidance for veterans and newcomers

Tuesday, May 9th, 2017


US Customs has updated web content to help users better understand the ACE Secure Data Portal —  perfect for members with existing portal access, and new trade members who are looking to gain access to the ACE Portal.

The new content will help ACE Portal users have a better understanding of the account process and to address frequently asked questions.  Note that none of the new content affects the structure of existing ACE Portal accounts.

And here’s a helpful one-sheet overview (click to expand):

ACE Basics - Portal Account

ATF importers: Updated ACE filing guide now available

Monday, May 1st, 2017

The latest from the Bureau of Alcohol, Tobacco & Firearms (CSMS 17-000248):atf-logo

The Department of the Treasury, Alcohol, Tobacco, Tax and Trade Bureau (TTB) has posted an updated ACE Filing Guide for TTB Related Commodities, V7.5.

A list of changes may be found on page 4 of the document.  The primary reason for the update is to provide guidance to the filer for the use of Disclaim Code “C” in the PG01 line of the TTB Message Set.

For all HTS numbers that identify a product regulated by the Alcohol and Tobacco Tax and Trade Bureau (TTB), in lieu of submitting the TTB Message Set, the filer may opt to meet TTB data requirements through other approved means.  Disclaim Code “C” is used to indicate that the filer is opting to meeting TTB data requirements through such means.  Refer to TTB regulations for more information about the requirements that apply to importers who elect not to file TTB data electronically.

TTB is also implementing business rules to enforce the regulatory requirements that have already been spelled out in the IG. If certain data is not provided, it will result in warnings to trade. Specifically:

  • for malt beverages, wine and distilled spirits, two PG14s must be provided
  • If a PG29 is present, the allowed unit of measure is only PCS
  • For a small set of TB1 flags, disclaim codes A and C are allowed; otherwise, only C is allowed.

Finally, TTB will begin enforcing their HTS flags per the schedule below.

  • TTB business rules in CERT: Expected no later than May 18, 2017
  • TTB flagging enforced in PROD: June 22, 2017







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 or

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.


  • 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

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.


  • 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.


  • 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.


  • 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

Tuesday, March 14th, 2017

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



Also posted on

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