Background

U.S. Customs and Border Protection has issued a proposed rule that would require the electronic submission of export manifest data for cargo transported by rail. Comments on this proposal are due no later than March 14.

CBP states there is currently a significant lack of electronic manifest data for rail exports that inhibits its efforts to ensure compliance with U.S. export control laws and regulations. Specifically, current CBP regulations only require the U.S. principal party in interest, the USPPI’s agent, or the authorized filing agent of a foreign PPI to electronically transmit certain electronic export information for rail cargo prior to departure from the U.S. Moreover, such information is generally only required for shipments that exceed $2,500 per Schedule B number and is not generally required for shipments to Canada.

In response, this rule would mandate the transmission via the Automated Commercial Environment of export manifest data (in addition to the electronic export information required under 15 CFR Part 30) for all cargo prior to departing the U.S. for Canada or Mexico by rail. The data elements would be the same mandatory, conditional, and optional data elements included in the rail EEM test CBP has been conducting since 2015. Most would have to be submitted two hours prior to departure of the train to a foreign port (rather than two hours prior to loading on the train), but the rule would add an initial filing for seven data elements to be presented 24 hours prior to departure: bill of lading number, total quantity, total weight, cargo description, shipper name and address, consignee name and address and Automated Export System exemption statement.

The outbound carrier would be responsible for transmitting the transportation data and empty container data and, if no other party elects to transmit it, the initial filing data and export manifest cargo data. Other parties with direct knowledge of the export information could also file initial filing data or export manifest cargo data, including USPPIs and FPPIs or their authorized agents, customs brokers, non-vessel-operating common carriers, freight forwarders, and Automated Broker Interface filers. Relevant bond regulations would be revised to provide CBP with the authority to impose liquidated damages on parties that do not provide the mandatory EEM data in the manner and timeframe required.

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