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Combined Cargo Release Entry/ISF Filing Now Allowed in ACE

Tuesday, February 10, 2015
Sandler, Travis & Rosenberg Trade Report

Effective Feb. 10, U.S. Customs and Border Protection is modifying its test of cargo release functionality in the Automated Commercial Environment by allowing certain authorized importers and licensed customs brokers to submit the ACE cargo release entry and the importer security filing in a combined transmission. CBP is also modifying the name of one cargo release data element.

Combined Entry/ISF Filing. Under ISF, importers are generally required to transmit to CBP certain cargo information consisting of 10 data elements at least 24 hours before goods are loaded onto an ocean vessel destined for the United States. The ISF importer is also required to transmit information regarding the container stuffing location and consolidator (stuffer) to CBP no later than 24 hours prior to arrival in a U.S. port or upon lading at a foreign port that is less than a 24-hour voyage to the closest U.S. port. ISF data may be filed via the same electronic transmission as entry or entry/entry summary documentation, and CBP currently accepts this combined transmission through the Automated Commercial System.

CBP will now be testing the filing of the combined transmission under ACE. To file such a combined submission the filer must meet the definition of an ISF importer in 19 CFR149.1 and be either a (1) self-filing importer or broker who has the ability to file ACE entry summaries certified for cargo release or (b) a self-filing importer or broker who has stated its intent to file entry summaries in ACE in its request to participate in the test. Parties seeking to participate in this test must use a software package that has completed ABI certification testing for ACE and offers the ACE cargo release message set prior to transmitting data under the test. Importers not self-filing must ensure that their broker has the capability to file entry summaries in ACE.

Combined filings must include (1) the ACE cargo release data elements and (2) the following three additional data elements: ship-to party, container stuffing location and consolidator (stuffer). All of the required information must be submitted within the applicable ISF timeframes. Test participants will not be able to utilize the ISF flexible filing provisions (which permit the ISF importer to submit an initial response for four of the data elements based on the best available data available and to update the information as soon as more precise or more accurate information is available) if they submit a combined filing. This limitation is necessary because CBP will use the cargo release information to make determinations regarding the admissibility of imported merchandise.

Although the ACE cargo release test is open to all importers and brokers filing ACE entry summaries for cargo transported in the air, ocean and rail modes, the ISF is required only for cargo transported by vessel. As a result, the combined submission is available only for cargo transported by vessel. In addition, entries requiring partner government agency information and certification from entry summary are not available for a combined filing at this time.

Cargo Release Data Element. The data element “Buyer Employer Identification Number (consignee number)” required under the ACE cargo release test is being renamed “Consignee Number.” CBP states that the definition of “Consignee Number” is specified in 19 CFR 149.3 and that this is the same definition that applied previously.

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