An industry advisory group is calling on U.S. Customs and Border Protection to review and consider changes to its Centers of Excellence and Expertise to reflect today’s trade environment.
According to documents prepared for a recent meeting of CBP’s Commercial Customs Operations Advisory Committee, the Centers have full operational authority to process post-release trade activities on an industry and account basis. They were designed to facilitate more uniform processing of imports, including by enabling better collaboration with other government agencies, and to improve enforcement efforts, including by focusing industry expertise on detecting illicit activity and increasing cooperation within CBP and with the trade community on specific issues.
CBP is now reviewing its implementation of the Centers to evaluate successes, efficiencies, and opportunities for enhancement. As part of that review CBP is partnering with COAC, which at its recent meeting called on CBP to update the models used to establish the Centers to better address current risks and priorities as well as emerging issues and threats. COAC explained that in the ten years since the Centers were established there have been a number of developments that have had “an extraordinary impact on the Centers’ operations,” including the imposition of Section 201 safeguard duties, Section 232 steel and aluminum duties, and China Section 301 tariffs; the enactment of the Enforce and Protect Act and the Uyghur Forced Labor Prevention Act; a significant increase in antidumping and countervailing duty cases; and the unprecedented expansion of low-value shipments.
COAC therefore recommended that CBP take the following steps to ensure that the Centers continue to adequately fulfill their mission.
- evaluate whether there are a sufficient number of Centers and whether any of them handles too many or too few commodity lines
- hire more import, entry, and drawback specialists, the number of which has remained relatively static for 20 years despite significant increases in workflow volume and complexity and CBP enforcement priorities
- rebalance the workloads and staffing of the different Centers, evaluate potential changes to the their organizational and funding structures, and review these factors regularly to “maintain needed levels of trade facilitation and streamline Center efficiencies”
In the meantime, COAC recommended that CBP take the following steps to improve existing operations.
- explore ways to achieve more robust and frequent communication between Center staff, Center members, customs brokers, and other trade entities, which “will help facilitate trade, enhance compliance, and create processing efficiencies”
- develop a public messaging system that can be used by the Centers to push out communications directed to Center members and other trade entities
- develop methods for enhancing connectivity between the many parties involved in Center operations, including internal CBP organizations such as the ports and the Office of Trade as well as external stakeholders such as partner government agencies
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