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Filing Limited AD Information Through ACE Document Imaging System to be Tested

Friday, November 20, 2015
Sandler, Travis & Rosenberg Trade Report

The International Trade Administration has announced plans to test the electronic submission to U.S. Customs and Border Protection through the Automated Commercial Environment’s Document Image System of forms and certifications that must be filed with CBP at the time of entry pursuant to an agreement suspending the ITA’s antidumping duty investigation of uranium products from Russia. This test will apply to all modes of transportation and all entry types filed in ACE at any port and will replace the current paper process for submitting the required documentation.

Examples of the types of scanned images that will be submitted via the DIS under this test are foreign government export licenses and export certificates, declarations of intent to reexport, processor certifications, end-user certifications, purchase and/or delivery orders, origin certifications and anti-circumvention certifications. Imaged documentation must be an accurate, complete, unaltered, unmodified and faithful copy of the original. Both the original and imaged documents must be retained by the filer and importer for five years from the date of submission and both are subject to CBP’s laws and regulations concerning recordkeeping.

The ITA states that entry data submissions will be subject to validation edits and any applicable participating government agency business rules programmed into ACE. Once entry data has cleared the initial stage of validation edits and PGA business rules, the filer will receive messages as to the status of the shipment from the time of entry data submission until the time of release. Once all of the PGAs have concluded their review of the shipment and have unset any remaining hold, CBP will send a “one USG” release message to the filer to indicate that all U.S. government filing requirements have been fulfilled at the port of entry for the shipment.

However, the ITA notes that the filing of the above documentation through the DIS does not replace the timely filing of the documentation required by the suspension agreement with the ITA through the Antidumping and Countervailing Duty Centralized Electronic Service System.

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