TSN Trade Members Say CBP Has Scaled-Back its Edit-Lite Proposal
During a February 22, 2008 press conference call, several trade members of the Trade Support Network1 discussed a variety of issues, including an update on the status of U.S. Customs and Border Protection's proposal to have a minimal number of edits and validations in the Automated Commercial Environment system (commonly referred to as "Edit-Lite").2
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CBP Agrees to Keep Admissibility, Release and OGA Edits in ACE
According to these TSN trade members, CBP has agreed to continue the edits related to admissibility, cargo release, and other government agencies (OGAs).
However, CBP still plans to remove certain edits, including those related to the calculation of duties and fees.
TSN Trade Members Ask that Other Edits be Kept Too
In addition, TSN trade members will be coordinating trade efforts to prepare and submit to CBP a paper containing recommendations on which additional edits it thinks CBP should reconsider keeping in ACE.
(CBP officials have charged the trade with the task of providing statistical evidence of the consequences to the trade that would result from the elimination of any edits of concern.)
Trade Also Reviewing Possibility of Including Eliminated Edits in Own Software
According to the TSN trade members, the trade is also reviewing the edits that CBP wants to eliminate to see if any of those edits can be done by the trade's own software provided that CBP is able to provide more data, more information attached to the tariff, better processes, etc. According to TSN trade members, the trade would also need something like a "rule book" from CBP which provides detailed documentation so that the trade knows how to do the duty and fee calculations.
Final Version of Edit-Lite Expected in ESAR A2.2 for Entry Types 01 and 11
For entry types 01 (Formal) and 11 (Informal), the final version of CBP's Edit-Lite is expected to be implemented as part of Entry Summary, Accounts, and Revenue (ESAR) A2.2, which is currently scheduled to be deployed in January 2009. ESAR A2.3 will be introducing other entry types and CBP will be reviewing the edits specific to those entry types and deciding which ones to include.
1TSN provides input into the design and development of modernization projects, such as ACE. CBP has been meeting with the TSN since May 14, 2001 regarding the development of ACE and has previously stated that the TSN has over 150 members of the trade community, including trade associations, importers, brokers, carriers, sureties, and others.
2In 2007, CBP proposed a reduced set of edits and validations called "Edit-Lite." As proposed, Edit-Lite would consist of fewer edits that ensure that (i) codes used within the "Entry Summary" message would be valid codes and (ii) any edits to make sure the data is valid within the context of the Entry Summary would be eliminated. In October 2007, the TSN responded to CBP's Edit-Lite proposal in a "white paper" which included a discussion of the problems that CBP and the trade were likely to face if Edit-Lite was implemented. (See ITT's Online Archives or 10/05/07 news, 07100505, for BP summary of the TSN's white paper.)
BP Note
In Commerce's ACE/International Trade Data System (ITDS) draft implementation plan, Edit-Lite was listed as a Census Bureau issue/concern.
Census stated that some of the edits it counts on to ensure that it gets accurate useable data will be dropped under Edit-Lite, including verifying that all the required Harmonized System codes are reported for transactions requiring more than one commodity code, and that both the country and commodity are eligible for claimed duty reduction or additional duty provisions.
Census notes that if errors are not caught by ACE (as they currently are by the Automated Commercial System (ACS)), Census (and most likely other participating government agencies as well) will have to either recreate these edits at considerable time and expense or risk publishing data showing trade preferences being granted to ineligible countries or commodities. (Draft implementation plan, dated 10/17/07, available at www.ocio.os.doc.gov/ITPolicyandPrograms/E-Government/PROD01_004274)
(According to a TSN trade member, most of these types of Census edits would be eliminated by Edit-Lite. Those CBP has decided to keep so far generally relate to making sure the quantities and value reported are within specific ranges for a particular tariff number.)