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Trade Community Seeking Further Modernization of CBP Revenue Collections

Wednesday, March 08, 2017
Sandler, Travis & Rosenberg Trade Report

The Commercial Customs Operations Advisory Committee approved March 1 more than a dozen recommendations on how U.S. Customs and Border Protection can continue to develop and improve its revenue modernization initiative. CBP officials said the COAC recommendations are consistent with their efforts and objectives.

CBP’s multi-year, phased revenue modernization initiative seeks to simplify and provide modern tools for the collection of duties, taxes, and fees; reduce the number of payments submitted via cash and checks at ports of entry; and improve documentation, training, and procedures. CBP believes the benefits of this initiative will include lowering transaction costs and administrative burdens that delay cargo and traveler movements; improving the agency’s ability to provide filers with an accurate, consolidated view of their financial transactions; and gaining access to real-time, reliable financial and operational data that will better inform decision-making and aid compliance with existing and emerging reporting requirements.

CBP has been working with COAC’s Trade Modernization Subcommittee to identify and collect from the trade and travel communities information on how to further improve its revenue collection processes and systems. As part of that effort, the subcommittee drafted, and COAC recently approved, the following recommendations.

- consolidate port-specific daily and monthly formal entry statements to one monthly statement, inclusive of all statements from all ports of entry nationwide

- any form of payment currently processed manually (e.g., duties, taxes and fees, single entries, reconciliation (NAFTA or value), post-entry adjustments via 28s, 29s, and post-summary corrections, liquidated damages, rate advances, and supplemental duty payments at liquidation) and/or voluntary tenders should be automated and available via ACE ABI, ACE AMS, the ACE portal and Pay.gov

- update CBP regulations to accept electronic payments

- allow individuals or companies who hold customs broker licenses to make payments through ACE for all brokerage-related fees

- create the ability for brokers for express consignment operators to pay duties, taxes, and fees electronically for daily consolidated informal entry filings

- require all truck carriers to submit an e-manifest through ACE prior to crossing

- enable the ACE application to allow for the set-up of a deposit account to be linked to an e-manifest so pre-payments may be automatically debited from the account based on the e-manifest

- leverage radio frequency identification technology, including on FAST cards, to collect single entry payments

- give truck carriers the ability to view a detailed history of their DTOPS-related transactions through the ACE portal, including all transactions associated with payments based on e-manifest

- create a smart phone app to provide a more efficient way of pre-paying fees

- allow shipment manifests, which contain a breakdown of cargo by entry type and payment, to be used to bill express consignment couriers for their express consignment fees or allow couriers to pay those fees using a pre-paid account in the ACE portal

- consider providing an incentive for ship agents and/or carriers to move toward e-payments (e.g., allowing the ship agent/payer 48 hours following vessel arrival to make payment if done via one of the approved e-payment methods)

- change the regulations to allow a more flexible method of overtime assessment that would meet both CBP and trade requirements

- create the ability to automate fees associated with partner government agency processing services (e.g., Fish and Wildlife Service overtime clearance fees and Department of Agriculture annual permits)

Please contact Trade Modernization Subcommittee Co-Chair Lenny Feldman at (305) 894-1011 for more information.

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