Annual Report on ITDS (Part I - Recommendations)
The annual report to Congress on the International Trade Data System program has recently been posted to the ITDS Web site. This report details the progress toward incorporating ITDS functionality into the Automated Commercial Environment, the status of Federal agencies in implementing ACE/ITDS, etc.
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(ITDS is a "single-window" system for electronic filing of import and export documentation. ITDS is not a separate computer system, but a suite of functions to be provided through ACE. ITDS is being developed and will be operated by U.S. Customs and Border Protection (CBP) with the collaboration of 40 other government agencies represented by the ITDS Board of Directors.)
This is Part I of a multi-part series of summaries on this report, and highlights the recommendations that were made for ITDS. See future issues of ITT for additional details from this report.
Highlights of ITDS Recommendations
The following are highlights of the recommendations in the report:
Agencies should accelerate development of plans for ITDS participation. Agencies, particularly those with an import safety mission, should accelerate their development of plans for their participation in ITDS, in order to take full advantage of ITDS capabilities.
Agencies should identify critical edits. CBP is considering whether to incorporate in ACE all "edits" now used in the current CBP trade processing system. (Edits identify errors in data submitted.)
This evaluation is fact-specific: some edits are critical, others may be less useful. ITDS agencies and CBP, however, may evaluate particular edits differently.Therefore, ITDS agencies should also determine which edits are critical for their purposes and provide timely input to the ACE development team.
(Note that CBP is discussing implementing a reduced set of edits and validations called "Edit-Lite." See ITT's Online Archives or 10/05/07 news, 07100505, for BP summary of TSN Transition Committee's response to CBP's proposal for "Edit-Lite.")
Implementation of "Access Filters" should be accelerated. The data exchange architecture intended to provide variable levels of access (limiting users to specified classes of data) has not yet been implemented. As a result, agency users can be required to have higher-level background checks and security clearances, the cost of which discourages use of the information available. Therefore, it is being recommended that the implementation of "Access Filters" be accelerated.
ITDS Board should be represented in ACE decision making process. To ensure that ITDS equities and interests are represented, the ITDS Board should be represented in the ACE decision making process.
Accelerate implementation of WCO Data Model messages. ITDS should accelerate implementation of World Customs Organization Data Model messages (new international standard for customs reporting) in order to reduce computer processing costs, allow rapid and accurate data exchange, etc.
Ensure that SDS established by January 1st. Work on harmonizing data among agencies, which is critical for eliminating redundant data demands, is not complete but has accelerated.The ITDS Board should ensure that an ITDS Standard Data Set (SDS) is established by January 1, 2008.
(See ITT's Online Archives or 11/08/07 and 11/09/07 news, 07110815 and 07110910, for Parts I and II of BP's summary of the Interagency Working Group on Import Safety's Action Plan, which includes ITDS recommendations that are mirrored in this ITDS report to Congress.
See ITT's Online Archives or 09/12/07 and 09/17/07 news, 07091215 and 07091715, for Parts I and II of BP's summary of the Working Group's initial report for improving imported product safety, which includes additional recommendations.
See ITT's Online Archives or 08/23/07 news, 07082305, for BP summary of CBP posting an updated ACE/ITDS SDS report to the trade, and the ITDS Megamtrix.)
ITDS Report to Congress (dated November 2007) available at http://www.itds.gov/linkhandler/itds/toolbox/library/resource_documents/itds_rpt.ctt/itds_rpt.pdf
BP Note
The Security and Accountability for Every (SAFE) Port Act of 2006 (Public Law 109-347), directed the Secretary of the Treasury to oversee the establishment of ITDS. The Secretary of the Treasury was directed to coordinate interagency participation, in consultation with an interagency committee that included agencies participating in ITDS and the Office of Management and Budget.
In addition, the SAFE Port Act codified the ITDS and mandated that all federal agencies that require documentation for clearing or licensing the importation and exportation of cargo shall participate in ITDS, unless waived.
(See ITT's Online Archives or 10/18/06 and 11/06/06 news, 06101820 and 06110625, for Parts X and XIII of BP's summary of the SAFE Port Act, which cover provisions pertaining to ITDS.)