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CBP to Test Expansion of Remote Location Filing Procedures

Monday, July 13, 2015
Sandler, Travis & Rosenberg Trade Report

As part of its continuing transition of all entry types from the legacy Automated Commercial System to the Automated Commercial Environment, U.S. Customs and Border Protection is planning to conduct a test concerning entries filed using remote location filing procedures. The initial phase of this RLF test will begin Aug. 12 and will continue until further notice.

Current Requirements. RLF is a special entry procedure that allows importers of record and brokers with a national permit to file an entry electronically from a remote location other than where the goods are being entered. Under CBP regulations, such entities must be operational on the Automated Broker Interface, which allows participants to electronically file required import data with CBP and transfers that data into ACE; the Electronic Invoice Program, a module of ABI that allows entry filers to transmit detailed invoice data through the Automated Invoice Interface; and the Automated Clearing House, a CBP-approved method for the electronic payment of duties, fees and taxes. Any invoice data required or requested by CBP must be transmitted electronically using EIP and any payment of duties, fees and taxes must be submitted through ACH. All entries filed using RLF procedures must be secured by a continuous bond.

RLF filers may certify release from summary; i.e., file an entry summary that serves as both an entry and an entry summary. RLF filers must file electronically (including by fax) all additional information required to be presented with an entry and entry summary that CBP can accept electronically, and must file in paper form at the port of entry any such information that CBP cannot accept electronically.

Test Coverage. Only entries filed through ACE that are certified for ACE cargo release from summary may be submitted under this test. For such entries, this test seeks to determine the viability, reliability and functionality of (a) expanding the entry types eligible for RLF procedures and the port locations where RLF entries may be filed (participants will be allowed to file entry types 01, 03, 11 and 52); (b) submitting invoices using the Document Image System instead of EIP for entries filed using RLF entry procedures; and (3) submitting single transaction bonds using eBond procedures for entries filed using RLF that require such a bond..

Participation. Any party who wishes to participate in this test must also be a participant in the DIS test and must provide CBP, as part of its request to participate, its filer code and the port(s) at which it is interested in filing RLF entries. Moreover, any test participant that wishes to, or is required to, submit a single transaction bond must also participate in the eBond test or use a surety or surety agent participating in the eBond test for the submission of the single transaction bond.

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