COAC Evaluates the Impact of the Office of Int'l Trade During its First Year
During the November 16, 2007 meeting of the Departmental Advisory Committee on Commercial Operations of U.S. Customs and Border Protection and Related Homeland Security Functions (COAC), members of COAC agreed on a letter which will be sent to CBP Commissioner Basham regarding CBP's Office of International Trade (OT) and its impact on trade one year after it was formed.
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The following are highlights of this letter:
Performance Measures to Improve Targeting and Reduce Dwell Times
The OT has identified several measures of performance and has developed baseline statistics for each measure. COAC states that its initial analysis of the results has provided clearer visibility where improved performance could result in a more favorable and efficient clearance process. For example, COAC notes in its letter that OT has identified measures for improved targeting and reduced dwell times at the pier or railhead.
Identify Why More Than 25% of Ocean Entries Are Filed After Arrival
COAC also found that importers and their brokers are filing entries after arrival more than 25% of the time for non-trade sensitive ocean shipments. The letter notes that both COAC and CBP have committed to identifying the root causes for this lack of efficiency and will determine what next steps should be taken to improve the timely filing of entries.
CBP Directives Have Been Sent to Field Without Required COAC Consultation
In its letter, COAC notes that during OT's first year, CBP issued several directives to the field without first discussing with COAC the potential impact to the trade. As an example, COAC cites a CBP directive instructing ports to penalize importers of textiles and wearing apparel for incorrect information declared at the time of importation and a directive which resulted in carriers having to redeliver containers back to U.S. ports of unlading, as their operations management were not prepared to comply with the new CBP directive.
COAC adds that under the SAFE Port Act, CBP has a responsibility to consult with COAC prior to implementation on changes to policy that can significantly impact trade and expressed concern that CBP observe this requirement.
(See ITT's Online Archives or 10/13/06 news, 06101315, for BP summary of the SAFE Port Act provision which requires CBP to seek the advice and recommendations of COAC on policies that have a significant impact on international trade and customs revenue functions.)
CBP Sought COAC Input in Developing 10+2 Policy
In its letter, COAC also states that an example of excellent communication between CBP and COAC was the development of the "10+2" or Security Filing policy which addresses advance trade data. According to COAC, the process that led to the 10+2 policy should serve as the model for CBP when developing requirements that will have a significant impact on the trade.
CBP Has Not Sought Input from COAC in Developing GTX
In contrast, COAC's letter states that the Department of Homeland Security's proposed Global Trade Exchange (GTX) database project has been prepared for public bid without CBP seeking the consultation and advice of COAC on the definition, design, and development of the program.
Expansion of Automated RLF and Paperless Processing
In its letter, COAC stated that CBP should begin to deliver on the 1993 Modernization Act and the original Automated Commercial Environment (ACE) commitments to (1) fully automate remote location filing (RLF) for all entry types, and (2) implement "pure paperless" processing for entries.
According to COAC, OT has given its assurances that paperless entries, except for Other Government Agency/Participating Government Agency (OGA/PGA) issues, will be forthcoming in the very near future. COAC sources state that this expansion of paperless processing will benefit cross border, Foreign Trade Zone, and other entries in need of nationwide paperless processing.
(These issues and others were brought to CBP by COAC in the context of the Customs-Trade Partnership Against Terrorism (C-TPAT) Green Lane discussions. See ITT's Online Archives or 08/28/07 news, 07082810, for BP summary of the August 2007 COAC meeting where COAC discussed previously requested C-TPAT benefits, including the expanded ability to file paperless entries and authorization to remotely file all types of entries.)
COAC letter (dated November 16, 2007) available via email by emailing documents@brokerpower.com