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CBP Planning to Advance Export Cargo Manifest Tests

Friday, January 22, 2016
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection recently provided an update on its three pilot tests evaluating the functionality of filing air, vessel and rail cargo export manifest data electronically to the Automated Commercial Environment. A similar test for truck export manifest data is under development. These pilots are expected to ultimately result in regulatory changes making the submission of export manifest data through ACE mandatory.

A status report provided at the Jan. 13 meeting of CBP’s Advisory Committee on Commercial Operations states that CBP anticipates implementing these pilots with multiple phases where participants can progress through each phase at their own pace in consultation with CBP. There will be three general phases for each pilot: (1) a test phase in which participants and CBP exchange electronic test data, (2) a data quality and analysis phase in which participants and CBP exchange production data and identify data quality issues and CBP performs risk assessment analysis and provides feedback to participants, and (3) an operational phase in which CBP performs real-time risk assessment of incoming data, places holds where appropriate and conducts inspections as warranted. CBP anticipates having multiple “progressing” segments in the operational phase of each pilot with adjustments made along the way based on lessons learned.

According to the status report, CBP has received a number of volunteers and established or identified the pilot groups for the air, vessel and rail pilots. Test data messages between a limited number of participants in the air and vessel pilots and CBP have begun, and one rail carrier has been testing data with CBP since August 2015. A working group recently discussed general principles for the truck pilot as well as challenges and current and future concerns. CBP anticipates that due in part to the complexities of truck operations crossing into Canada and/or Mexico, a Federal Register notice announcing the truck pilot will take some time to publish.

CBP plans to expand the test phase for the air, vessel and rail pilots over the next 30-90 days and to seek to increase the exchange of production data over the next 30-120 days. CBP will also evaluate the additional volunteers it continues to receive for participation in the expanded phase of the pilots. Further, CBP will be seeking to establish linkages/recognition between the trusted trader and export manifest pilots and will work cooperatively with the Census Bureau and COAC to find a solution for a new post-departure filing (option 4) regime.

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