TSN Transition Committee Responds to CBP's Proposal to Have Minimal Edits in ACE
The Trade Support Network Transition Committee has issued a "white paper" which responds to a proposal by U.S. Customs and Border Protection to have a minimal number of edits and validations in the Automated Commercial Environment system.
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CBP is Considering a Reduced Set of Edits and Validations called Edit-Lite
According to the white paper, CBP currently has 1,468 error messages listed in the Automated Broker Interface (ABI) Error Message Dictionary, which are currently used by ACS.
CBP is discussing implementing a reduced set of edits and validations called "Edit-Lite." Edit-Lite would consist of minimal edits that ensure that codes used within the Entry Summary message would be valid codes. Any edits that make sure the data is valid within the context of the entry summary would be eliminated.
Examples of edits proposed for elimination. According to the TSN Transition Committee, examples of the edits that would not be performed under CBP's Edit-Lite proposal for ACE include:
Total Payable ADD/CVD does not match CBP's Calculation
Additional HTS Numbers are missing
Duty Not Allowed - Tariff Duty Free
Duty Computation Date > 60 days in the Future
GSP Claim Invalid for This Tariff
Incorrectly Estimated MPF Maximum
MPF Not Allowed - Set Component
Mail Fee Missing
License/Certificate/Permit Code Missing
Export Date cannot be > Filer Entry Date
Value exceeds informal limit for Article
Broker Invalid for District
Formal Quota Entry Required
Agr Cheese License Amount Exceeded
Country/Case Number Mismatch
TSN Transition Committee Warns of Problems with Edit-Lite
The white paper warns that if Edit-Lite is implemented (1) ABI representatives would have to field more calls from filers with confusing problems; whereas the filers previously would have gotten error messages from the edits and fixed the problems up front; and (2) inspectors, entry specialists, and import specialists would be spending more time chasing down "false positives" based on preventable errors, taking them away from more important tasks.
Other expected effects of Edit-Lite. The following are some of the other expected effects of CBP's Edit-Lite proposal (as listed in the white paper, partial list):
The broker will face an increased liability risk for errors.
The trade will be exposed to higher risks of penalties for non-compliance.
The fewer edits of Edit-Lite will likely lead to a high volume of data inaccuracies that will limit the statistical products Census can produce for other participating government agencies (PGAs) and data users.
Application Development for future rules and trade programs will not be uniform throughout the trade.
The cost of software development for the trade will increase as software vendors have to raise prices due to increased costs of development and on-going edit updates.
There are some brokers and self-filers who might try to avoid certain regulations or expenses.
Transition Committee White Paper (dated September 2007) available at
http://www.acetransition.net/images/ACE_Edit-Lite_Trade_Position_-_Final.doc. (click cancel when prompted for a user name and password to see document.)