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Drawback

What’s up with the ACE Post Release Deployments? Get the latest here.

Wednesday, August 30th, 2017

ace-logoAs a follow up to our June 27th, 2017 blog, announcing the delay of CBP’s July 8th ACE post release deployments, which was a follow up to our June 9th, 2017 blog announcing CBP’s deployment of ACE post release, which was a follow up to our January 10, 2017 blog, etc…

You get the picture.  Deploying ACE post release capabilities has been an on again, off again proposition for CBP, though almost all of the capabilities are ready and available for trade testing.

CBP has recently modified the deployment schedule to include a phased approach, and today, CBP has updated their ACE deployment schedule, per CSMS# 17-000525.  To see the current ACE Deployment Schedule, Click here

Also, for additional clarification on these phased deployments, below is an email from 7/27/17 to the members of the TSN and the trade…

Dear Trade Support Network,

On June 27, 2017, CBP announced a delay in the deployment for the Automated Commercial Environment (ACE) post release capabilities that had been scheduled for July 8, 2017.  This deployment includes liquidation (with the exception of the previously deployed electronic posting of the Notices of Liquidation on CBP.gov), reconciliation, drawback, duty deferral, statements, collections and the Automated Surety Interface (ASI).  With the exception of the collections functionality, these remaining post-release capabilities are ready and available for trade testing. Based on the results of rigorous testing of the collections capabilities, CBP has modified the deployment approach.

 Since the collections capabilities are largely inward facing, the replanned deployment strategy will enable us to separate collections and deploy the other post release capabilities of ACE core using a phased approach.  Developers are working software changes that will allow ACE deployment of these post release capabilities, while also ensuring that they continue to interface seamlessly with collections in the legacy system.

 The current phased deployment schedule is as follows:

  • ACE Deployment G (September 16, 2017) – Non-ABI Entry Summary/Lineless (for CBP only), Duty Deferral, e214 (electronic Foreign Trade Zone admission) and Manufacturer ID Creation
  • ACE Deployment G (December 16, 2017) – Statements
  • ACE Deployment G (February 24, 2018) – Reconciliation, ACE Core Drawback and Trade Facilitation and Trade Enforcement Act (TFTEA) Drawback, Liquidation and Automated Surety Interface (ASI)

 Between February 2018 and February 2019, trade users will have the option to file either Core Drawback or TFTEA Drawback.

  • Core Drawback includes the following:
    • Consolidation to entry type 47
    • For electronic claims, submission of entire drawback package electronically
    • System validations
    • Integration with post release processes
    • Improved system controls
    • Does not require line level reporting
  • TFTEA Drawback includes the following:
    • Substitution based on 8-digit HTS or Schedule B number
    • Requirement to file all drawback claims electronically
    • Recordkeeping requirement three years from date of liquidation
    • All claims due five years from date of importation
    • Reliance on documents kept in “normal course of business”
    • Requires line level reporting

 Please note the following: 

  • CBP will be retraining our personnel and providing updated materials on each capability prior to these deployments. 
  • The re-planning required to address the issues with collections capabilities is continuing. 
  • The ABI Query for Foreign Currency Rates will remain in ACS until ACS is no longer available.  In parallel, currency rate calculation information is also posted on www.cbp.gov/ace.
  • CBP will develop and deploy TFTEA drawback capabilities in accordance with the legislative mandate.

 Please share with you trade associates.

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

 

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

 

CBP offering free Simplified Processes Initiative webinar

Wednesday, March 22nd, 2017

The Simplified Processes Initiative (SPI) is an effort to develop a transformation strategy to optimize the process of importing goods through collaboration with the trade and CBP.

Click here to view a summary of the information that presenter Randy Mitchell, Director, Commercial Operations and Entry Division, Office of Trade, Trade Policy and Programs will cover during this free webinar on March 24 from 3 to 4 p.m. ET.

 

Screen Shot 2017-03-22 at 8.54.41 AM

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.

How will CBP’s drawback program change in the coming months?

Wednesday, February 1st, 2017

refund

The Trade Facilitation and Trade Enforcement Act of 2015 included a sweeping “game-changer” for the CBP drawback program, providing numerous, significant enhancements to the drawback laws under 19 U.S.C. § 1313, long-sought over the past decade by both CBP and the trade.

Section 906, Drawback and Refunds, of the Act goes far to strengthen the drawback legal framework and CBP’s ability to more accurately and objectively administer drawback.

Now you can learn more about the upcoming changes in CBP’s electronic newsletter.

From CSMS #17-000047:

In support of upcoming drawback program changes mandated by the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), US Customs has published the Drawback Simplification Newsletter on CBP.gov. This newsletter provides TFTEA Drawback development and deployment information for the trade community. CBP intends to update information each month and plans to publish the newsletter on its website through February 2019.

ACE: Full core trade processing, including post-entry, deploys January 14!

Tuesday, January 3rd, 2017

 

Calendar Icon with long shadow. Flat style. Date,day and

 

US Customs is preparing to deploy capabilities that will complete the delivery of core trade processing in ACE. The date for the deployment and mandatory transition of these capabilities will be January 14, 2017.

The capabilities in the deployment include: drawback, duty deferral, liquidation, collection, statements, and reconciliation. Please note: Importer Security Filing (ISF) is transitioning on January 14 as well. Beginning January 14, 2017 transactions supporting these capabilities must be filed in and processed through ACE. Submissions to CBP’s legacy system, the Automated Commercial System (ACS), will no longer be supported.

Full details on the transition of each of the capabilities, reference materials, and technical documentation are available on CBP’s website through the following links:

 

For details on what specific applications are transitioning from ACS to ACE and what transactions and queries will no longer be available, please reference CBP’s ACS to ACE Application Transition Plan. Any items on the spreadsheet marked January 2017 will no longer be available beginning January 14 2017, including items under ‘Scheduled to Transition’, ‘Available in ACS and ACE’, and ‘Will Not Transition’.

Please note:
  • The January 14, 2017 deployment does not include Manufacturer ID Add (MID), as this capability must be deployed at the same time as Foreign Trade Zone (FTZ) Admissions (e214s). Details on these capabilities will be made available through future communications.
  • The ACE Product Code query will be removed from and no longer supported in ACE.
  • For further details on CBP’s transition to ACE, visit the ACE Mandatory Use Dates page, or reference the ACE Entry Summary Business Process Document for policy and business process flows.
  • For technical support during the transition, contact your company’s assigned Client Representative. During the deployment period Client Representatives will have access to additional headquarters policy, operations and technical personnel to expedite any transition issues. More details on this additional support will be made available in early January.
  •  Reports in support of the capabilities being deployed will be made available after January 14, 2017. After deployment of capabilities into production, additional time is needed to migrate and synchronize legacy data to ensure accuracy of data prior to reports being made available. More details will follow as various reports become available.

 

 

 

LA trade professionals: Attend WITOC’s duty refunds and drawback workshop

Thursday, October 27th, 2016

 

What’s trending for exporters and importers?

Do you know about the new duty drawback law?

Women In Trade – Orange County is ready to help with this informative program!

Screen Shot 2016-10-27 at 8.35.46 AM

 

Many global businesses are unaware of options that maybe available to them to take advantage of proven duty saving programs to help reduce import and export costs, increase profitability and gain competitive advantage in U.S. and foreign markets.  Join us and learn what’s trending in the international trade arena for multinational companies, importers and exporters about one program that’s sure to be of interest – Duty Drawback – A Refund of Certain Exports.  New rules are soon to go into effect.

This workshop will provide an overview of the program, some of the noteworthy requirements and the associated risks.  There will be a discussion of the latest trends in using this program, the new drawback law, best practices and tips for regulatory compliance.

  • This workshop is designed for Vice Presidents, Directors, Managers, Supervisors, Corporate Counsel and other professionals of companies who are importing and/or exporting with responsibility for trade compliance, import/export processing, supply chain and logistics management, sales and finance.
  • International trade-related service providers in legal, customs brokerage, freight forwarding, consultants, banking and city economic development will also find this workshop of value.

 

Speaker:  
Founder and President
AMH CUSTOMS CONSULTANTS
Newport Beach, California
Date:
November 17, 2016
3350 Avenue of the Arts
Costa Mesa, CA 92626
Cost:
$95 Members ; $125 Non-Members
          $550 Corporate Table of 6
register-now-button-pilll-red-hi

 

 

 

ACE: newly revised CBP guidance for Jan 2017 post-entry capabilities

Tuesday, October 4th, 2016

ace logo 2016

Now that US Customs has postponed deployment of ACE post-entry functionality until January, it has published updated guidance for each of the delayed capabilities:

Breaking news! ACE Oct 29 deadline for post-release functions moved to January 2017

Wednesday, September 28th, 2016

ace logo 2016As announced on today’s ACE Technical Call with the trade:

US Customs continues to assess stakeholder readiness for the mandatory transition of post-release capabilities in ACE.  In order to allow additional time for all stakeholders to prepare for this transition, and to provide the opportunity to solicit and receive public comment on the associated regulatory changes, CBP is rescheduling the October 29, 2016 transition.

This transition includes the mandatory use of ACE for liquidation, drawback, reconciliation, duty deferral, collections, statements, and the Automated Surety Interface. CBP is targeting January 2017 for the revised deployment and mandatory date and will provide additional clarification regarding the precise transition date in the coming weeks. 

CBP official notice here.