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Don’t miss FDA’s upcoming webinars on ITACS – September 5th, 7th & 11th

Tuesday, August 22nd, 2017

fda1On August 21st CBP sent out CSMS message no. 17-000506 on behalf of the U.S. Food & Drug Administration.

The message announced three identical webinars, to be held September 5th,  7th, and 11th which will provide information on the evolution of FDA’s Import Trade Auxiliary Communications System or ITACS system “to ensure that trade users are familiar with and understand the new ITACS Account Management functionality.”

The webinars will include the following:

  • An overview of current ITACS functionality
  • Background and overview of the new ITACS Account Management functionality
  • Creating an ITACS Account
  • Retrieving Notices of FDA Action from ITACS
  • Managing your ITACS Account, Users and Groups
  • Where to find ITACS and ITACS Account Management resources

If your imports are regulated by the FDA we strongly suggest that you attend one of these webinars.  Click here for more detailed information and to register.

Updated CBP document on entry types by PGA – shows FTZ flexibility

Tuesday, July 25th, 2017

cbp entry type pgaOn July 18th, 2017 CBP posted the recently updated ‘Entry Types by PGA’ document.  This document advises the trade which CBP entry type codes will require Partner Government Agency data, and when; either at cargo release, summary or other.

The majority of PGA’s require that their PGA Message Set be sent at the time of Entry (Cargo Release).

However, with the implementation of ACE, and based on feedback from the Trade, some flexibility has been provided for Foreign Trade Zone (FTZ) entries.  For instance, with FTZ for Vehicles & Equipment regulated by the EPA, filers have the option of filing the EPA message set at the time of filing the type 06 Entry (Cargo Release) or, if utilizing the weekly entry process, they can send it at the time of transmitting the Entry Summary.

Lost your tariff number? Wondered the status of GSP? Read on…

Wednesday, July 12th, 2017

HTS UPDATE IMAGE

 

On June 29th CBP published CSMS message no. 17-000381 announcing the availability of Harmonized System Update (HSU) 1704, which went into effect on July 1, 2017.

This USHTS update contains modifications mandated by the 484 F Committee (the Committee for Statistical Annotation of Tariff Schedules), adjustments to several Participating Government Agency (PGA) indicators, and staged rate duty reductions as a result of Presidential Proclamation 9466 (to Implement the World Trade Organization Declaration on the Expansion of Trade in Information Technology Products and For Other Purposes).

The modified records are available to all ABI participants and can be retrieved electronically via the procedures indicated in the CATAIR.  CustomsNow clients have the ability to review the HTS numbers that are valid on/after July 1st and mass update their product classifications accordingly.  The official HTS 2017 and update change record can be viewed at the USITC website.

In addition to these updates, CBP advised that as of its publication, the latest GSP proclamation had not been signed.  CBP is expecting the proclamation to have a July 1st effective date as well, but due to recent differences between the draft documentation and the final legislation, CBP was unable to make the necessary modifications until the proclamation is official.  Once it has been signed, CBP will begin updating the system. When the changes have been completed another HTS update will be created and the associated CSMS message will be posted.

Hot off the press! July 8, 2017 ACE Deployment Postponed

Tuesday, June 27th, 2017

ace-logoHold that thought….

CBP has just announced that the July 8th scheduled deployment for Entry Summary functionality to ACE has been postponed.  Though just announced under a month ago, CBP has determined that a few more things need to be worked about before the deployment.

Read more of the history on this topic here.

Per CBP, “The rescheduled deployment date will be published in a Federal Register Notice at least 30 days in advance of the actual deployment/mandatory transition.”

A CSMS message from CBP should follow shortly.

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

Friday, June 9th, 2017

 

goodbyt

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

Picture1

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

ace-logo

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 ASKACE@cbp.dhs.gov.

*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