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New Periodic Consolidated Correction Feature for Importer Self-Assessment Participants

Wednesday, October 29, 2014
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has recently launched a limited pilot program allowing for wholesale entry corrections on a periodic basis. The Periodic Consolidated Correction pilot is currently available only to Importer Self-Assessment certified importers within the electronics Center of Excellence and Expertise. The pilot appears to have received a mixed reaction, with some support from importers but disapproval by customs brokers as well as CBP’s ACE office.

“One big reason some companies are not allowing their customs brokers to file entries in the Automated Commercial Environment is the lack of an option for correcting multiple entries at one time, similar to the current quarterly post-entry amendment,” said Sandler, Travis & Rosenberg consultant Tom Gould. “Additionally some companies are not switching to ACE because they file their own PEAs and don’t want to pay their brokers to file post-summary corrections. The PCC is meant to alleviate some of these concerns by allowing ISA importers in the electronics CEE to file a PCC directly with CBP (that is, without having to go through the broker) and correct multiple entries at one time.”

Pilot participants will initiate the PCC via submission of the following to the electronics CEE email inbox or the Document Imaging System. (CBP notes that importers of record will be required to file separate PCCs for each IOR number covered by the CEE.)

- a cover letter including reason for submission, date range of covered entries, amounts paid via PCC for duty, taxes, fees and interest, declaration of waiver regarding refunds, importer of record name/number, and a statement of waiver of any claim for refund, via drawback, reconciliation or protest/petition, of the additional monies after PCC approval

- a spreadsheet containing the importer name/number, calendar year, entry number, liquidation date, country of origin, tariff number, applicable correction (additional value, new tariff number, etc.), duty rate, duty change, harbor maintenance fee change, merchandise processing fee change, and totals

CBP states that PCC filings are only acceptable as a form of tendering payment to CBP. Refunds can only be considered on an entry-by-entry basis and should be filed separately from a PCC by filing a PEA, PSC or protest.

CBP states that pilot participants should see a significant reduction in the amount of time and resources dedicated to resolving wholesale entry corrections as well as a more collaborative approach with the electronics CEE. In addition, CBP anticipates benefits for itself such as increased accuracy of entry data, more timely payments, and a reduction in the administrative burden of processing several reconciliation entries, liquidated damages and penalties.

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