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Practice Areas

Improving Entry Summary Process is Aim of Government-Industry Group

Monday, July 28, 2014
Sandler, Travis & Rosenberg Trade Report

Representatives from U.S Customs and Border Protection, partner government agencies and the trade community, including Sandler, Travis & Rosenberg’s Lee Sandler, are working to modernize the entry summary and revenue collection process to align with current business practices. The Simplified Summary Working Group has scheduled a series of meetings through October, at the end of which it plans to develop a concept of operations that includes business requirements, assumptions and recommendations for implementation of an alternative process, and related policy changes.

At their first session held July 15-17, participants decided that a final proposed alternative should align Simplified Summary with the account management approach for trusted traders, decouple entry from entry summary, incorporate elements of the Importer Activity Summary Statement, allow entries to be liquidated by line, permit importers to aggregate entry releases by month and make corrections, select filers based on feasibility and financial risk tolerance in the pilot program, and apportion duties, taxes and fees (e.g., the merchandise processing fee and Harbor Maintenance Tax) at the line level and aggregate them to one payment. Participants said the goals of Simplified Summary include building on prior efforts related to the trusted trader concept, automating and streamlining reporting and payments, reducing the number of “touches” by customs brokers, and increasing CBP’s trust in filers’ entry summaries.

The following actions are planned in preparation for the August session.

- review Canada’s Customs Self-Assessment program and identify where best practices can be adopted or replicated

- map out existing and ideal entry summary and revenue collection processes, highlighting all documentation and payment activities, data requirements and deadlines, to identify where processes could be streamlined

- determine the timeline for developing the collections and liquidation modules of the Automated Commercial Environment, existing business requirement documentation being used for that development, and the near- and long-term inputs needed to inform future development related to data collection and payment processing

- examine current government accounting standards to determine auditing requirements related to data collection and payment processes

- informally survey users within CBP and the trade community on the decision points identified above

- identify individuals to invite to the August session, including representatives from the customs broker community

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