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CBP Provides Additional Information on New Centers of Excellence and Expertise

Wednesday, January 18, 2012
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has posted to its Web site additional information about the centers it is establishing to speed the processing of imported goods. The first two – the Center of Excellence and Expertise – Electronics in Los Angeles and the Center of Excellence and Expertise – Pharmaceuticals in New York – were created last October, and others are anticipated in 2012. Each CEE will seek to increase the uniformity of practices across ports of entry, facilitate the timely resolution of trade compliance issues nationwide and further strengthen CBP knowledge on key industry practices.

Scope of CEEs. CBP states that each CEE will address an entire industry and provide a single point of contact for questions or concerns related to that industry. This will enable CBP trade personnel to specialize in a key industry, building advanced knowledge in the intricacies of particular business practices, processes and products. CEEs also will serve as a ready source of clear and definitive information for trade and government partners on CBP requirements and best practices. As the CEEs expand they will provide “one-stop” processing for trusted traders in a particular industry, processing entry summaries and subsequent activities (e.g., post-entry amendments, protests) for trusted traders.

The trade community can contact CEEs for assistance in the following areas: technical guidance on covered imports, clarification of CBP policies and procedures, assistance with CBP requests for information/action (CF-28s, CF-29s, etc.), assistance with lengthy cargo holds, and information regarding counterfeit/substandard imports.

Trusted Traders. For the moment, a trusted trader is an importer that is Customs-Trade Partnership Against Terrorism certified (tier 3 or 2) and a member of the Importer Self-Assessment program. As the CEEs expand CBP will look for opportunities to work with industry on expanding the definition of a trusted trader.

Import Processing. CBP states that the process flow for entries and entry summaries will not change and that the location of CBP processing for post-release aspects of trusted trader shipments will simply be moved from ports of entry to the appropriate CEE. For example, an electronics importer may currently import through 60 ports of entry, with post-release processing being done at each location. Once the CEEs are fully staffed and have necessary trade functionality they will handle such processing, leading to greater uniformity in decision making.

Training. CEEs will develop and foster training initiatives for both agency personnel and members of the trade community. This may include collaborative efforts with the private sector to enhance agency understanding of the industry at large. CEEs can also serve as an important resource for small and medium-sized importers who may not have large compliance departments.

Other Government Agencies. CEEs will be expected to partner with OGAs and promote the adoption of risk management and segmentation practices that will result in even greater facilitation of legitimate trade and enhanced enforcement activities. CBP would welcome OGA participation and staffing in the CEEs whose industries are regulated by those agencies.

Expansion. CBP plans to establish additional CEEs over the next three years and to have all imported commodities covered by CEEs by the end of that time.

Account Managers. All trusted partners within a CEE-covered industry will continue to have account managers assigned to them.

Cargo Security. CBP states that cargo security aspects will remain within the current organizational elements but that CEEs will play an integral role in enhancing the link between security and trade functions as they evaluate the impact of security efforts on their specific industries and accounts.

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