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In-Bond Regulatory Changes Pushed Back Six Months

Monday, January 08, 2018
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has extended for six months the implementation dates for a September 2017 final rule amending the in-bond transportation regulations. Changes made by this rule include eliminating the paper in-bond application (CBP Form 7512) and requiring the application to be filed electronically, mandating additional data elements on the application (including the six-digit HTSUS number), specifying a 30-day window for in-bond goods to be transported between U.S. ports, and revising the timeframe for reporting or updating in-bond records.

(Click here to register for our Jan. 10 webinar on in-bond and other CBP priorities for 2018.)

According to CBP, the new implementation schedule is as follows.

- As of July 2 CBP will no longer accept paper 7512s or input the data on the trade’s behalf; instead, electronic filing of new in-bond transactions will be the responsibility of the trade. However, paper forms or other paper alternatives (e.g., screen prints or plain paper documents) will be accepted as part of enforcement processes at the border or verification/audit operations such as warehouse withdrawals, foreign-trade zone exports, and transfers or vessel/aircraft supply operations where additional information is required on paper forms that is not provided for electronically.

- As of Aug. 6 electronic reporting of all in-bond transactions will be mandatory and CBP will no longer accept paper 7512s to perform arrival and export functionality, which will be the requirement of the carrier. CBP will also require electronic reporting of (a) diversion to a port other than reported on the original in-bond and (b) bonded cargo location (FIRMS code). In both cases, an ACE edit will reject arrival if reporting is not done electronically.

- CBP has still not set a date for implementation of the provision requiring the six-digit
HTSUS number for immediate transportation movements.

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