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In-Bond Change Enforcement Delayed Six Months

Thursday, August 02, 2018
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has deferred enforcement of certain aspects of its updated regulations on in-bond movements until Feb. 6, 2019. A CBP notice states that during this period the following policies will be implemented.

- In-bond shipments that arrive on a mode of transport other than air and are subsequently transferred to air for exportation or movement to a U.S. port of entry may continue to be arrived and exported by CBP.

- In-bonds that originate in the U.S. from either bonded warehouses or foreign-trade zones and are subsequently exported by air may continue to be arrived and exported by CBP.

- The use of FIRMS codes at arrival will not be enforced for those reporting electronically.

- No automated edits in ACE will be implemented, thus avoiding system reject messaging.

- CBP officers at the port will assist traders with in-bond arrival and export reporting as needed.

- Timeframe enforcement for arrival and export reporting beyond the two business days specified in the regulations for those reporting electronically will be extended to four days.

CBP states that while ports are instructed to issue warnings rather than penalties during this six-month period they will maintain the discretion to fully enforce for egregious or continued violations or a lack of demonstration of good faith efforts.

Additionally, until further notice CBP will (a) provide a stamp or perforation on a CBP Form 7512 verifying exportation upon request of the carrier (which must provide proof of exportation or physical verification), and (b) continue to defer enforcement of the submission of the six-digit HTSUS number.

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