Full ABI Edits for Prior Notice of Imported Food Delayed to May 19, 2004
U.S. Customs and Border Protection (CBP) has issued an administrative message announcing that full Automated Broker Interface (ABI) edits for prior notice (PN) of imported food will not be turned on until May 19, 2004 (from May 13, 2004).
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According to sources at the Food and Drug Administration (FDA), these full edits are the cornerstone of Phase 3 of the FDA/CBP discretionary enforcement plan for PN, and that effective May 19, 2004, certain edits and validations that generated warning messages in Phases 1 and 2 will generate fatal errors in Phase 3.
CBP explains that the change from warning messages to fatal messages applies only to PN data submitted with entries (program applications HN (border cargo release), HI (cargo release), and EI (entry summary)). The change does not apply to independent PN transactions submitted through application WP (in-bond).
CBP states that it is the responsibility of the ABI filer to correct all errors in the transaction and retransmit the corrected entry for FDA PN and admissibility processing.
PN Entry Data, That If Omitted Will Result in Fatal Errors
FDA entries with lines subject to PN must follow the same edits and validations of the current FDA entries in the CBP FDA interface. In addition, the FDA PN entry records must contain the following data:
FD01 and FD05 - Affirmation of compliance codes and qualifiers as follows: the first PN affirmation of compliance must appear in the FD01 record. If the filer submits a previously received PN confirmation number (PNC) in lieu of PN data, the PNC must appear in the FD01 record. If the PNC is sent in the FD01 record, CBP states that additional PN affirmations of compliance should not be transmitted in the FD05 records.
FD02 - The first quantity and unit of measure (positions 5-14 and 15-18). A minimum of one quantity and unit of measure must be present.
FD04 - The contact name, both first and last, and the telephone number (positions 19-28, 29-38) must be present.
CBP states that ACS generated warning messages if any of the above data elements were missing during Phases 1 and 2 of the FDA PN. However, effective May 19, 2004, the ABI filer is responsible for correction and retransmission of any PN entry that generates a fatal error because any of the above elements is not transmitted.
17 Affirmations of Compliance, if Omitted, Will Result in Fatal Errors
Effective May 19, 2004, CBP states that the following 17 affirmations of compliance will generate a fatal (reject) message if they and a qualifier are missing from the PN transaction (previously a warning message would have been generated):
Submitter - SLN, SFN, SPN, SFX, SEM, SCN, SA1, SAC, SAS, SCZ, SCC, SFT
Anticipated Arrival Information - APA, ADA, and ATA
Owner - OFT
Country of Shipping - CSH
(The above-listed acronyms are described in CBP Adm 03-2619. See ITT's Online Archives or 11/06/03 news, (Ref: 03110620), for BP summary of Adm 03-2619.)
7 Warning Messages Will Become Fatal Errors in Phase 3
According to CBP, the following are warning messages that will be changed to fatal errors in Phase 3, effective May 19, 2004:
| FDP | Required PN not submitted |
| FGF | Contact name required for FDA PN |
| FGG | FDA PN mandatory field missing |
| FDH | FD-AOC invalid contact phone number |
| FGI | "PNC" must be in the FD01 record |
| FGJ | Quantity 1 required for FDA PN |
| FGM | FD04 contact name, telephone number required FDA PN |
See administrative message for list of 18 messages that CBP states are continuing as fatal errors.
CBP Summary
In summary, CBP states that effective May 19, 2004, if either a PNC or PND (PN disclaimer) is not transmitted, lack of the following additional information will cause an entry to be rejected:
Quantity
Contact name and contact telephone number
Submitter (12 affirmations of compliance)
Anticipated arrival information (to include port, date, time)
Owner firm type
Country of shipping
CBP reiterates that the above applies only to entries submitted in applications HN, HI, and EI.
-questions should be directed to client representatives
(See ITT's Online Archives or 04/21/04 news, 04042105, for BP summary of CBP's clarified/re-issued administrative message on full implementation of ABI edits.
See today's ITT, 04051410, for BP summary of CBP administrative message announcing Phase 3 delay and FDA's Compliance Policy Guide.)
CBP Adm 04-1240 (dated 05/12/04) available via email or fax by emailing documents@brokerpower.com
BP Note
See today's ITT, 04051499 5 for list of certain discrepancies in this CBP notice.