CBP Agrees to Carry Over 24 High Priority ACS Edits in ACE
During the May 9, 2008 meeting of the Departmental Advisory Committee on Commercial Operations of U.S. Customs and Border Protection and Related Homeland Security Functions (COAC), CBP officials announced that CBP has agreed to carry over into the Automated Commercial Environment (ACE) 24 edits which the Trade Support Network had asked CBP to keep.
Sign up for a free preview to unlock the rest of this article
Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today!
(In 2007, CBP proposed that 63 current Automated Commercial System (ACS) edits1 specific to the commercial preparation of the Entry Summary not be carried over into ACE. The TSN reviewed and evaluated CBP's proposal and responded with 24 edits that TSN members believed were critical to keep. CBP's proposal was originally called "Edit Lite," but is now referred to as '"Edit Modification.")
TSN Was Concerned That Insufficient Edits Would Increase Trade Costs, Etc.
The TSN had expressed concerns that CBP's Edit Modification proposal would create an insufficient number of edits which could significantly increase the trade's costs and liability risks, as the discovery of errors would occur more frequently "after the fact" during compliance auditing. The TSN has previously noted that as the majority of filers are small to medium size companies, this would prove to be a major burden on them.
24 ACS Edits to be Retained in ACE
The following is a list of the 24 ACS edits characterized by the TSN as high priority and which CBP has agreed to incorporate into ACE:
Manual Surcharge Entry Type Restriction
Informal Entry/Value of Goods Restrictions
Trade Agreement to Article Validation
Computed Article Duty to Total Article Estimated Duty Validation
Non-Quota Entry Type Quota Restriction Validation
IR Tax Mandatory Reporting Validation
Computed IR Tax to Estimated IR Tax Validation
Formal Merchandise Processing Fee (MPF) Free Reporting Restriction
Formal MPF Mandatory Reporting Validation
Computed Formal MPF to Reported Formal MPF Validation
Harbor Maintenance Fee (HMF) MOT Reporting Restriction
HMF Set Component Reporting Restriction
HMF Mandatory Reporting Validations
Computed HMF to Estimated HMF Validation
Other Fee Mandatory Reporting Validation
Cotton Fee Reporting Exemption Validation
Organic' Product Fee Reporting Exemption Validation
Informal Article Combination Restriction
Dutiable Mail Fee Reporting Requirements & Restrictions
Informal MPF Fee Reporting Requirements & Restrictions
Formal MPF Total Fee Amount Validation
HMF Total Calculated Amount Validation
Other Fee Total Computed Amount Validation
Grand Total Calculated Duty Validation
24 Edits Will Not be Incorporated into ACE When ESAR A2.2 is Rolled Out
According to CBP sources, the 24 edits will not be in place when ESAR A2.2 is rolled out in January 2009. However, they are expected to be incorporated into ACE sometime before entry summary filing in ACE becomes mandatory (i.e., when all entry types can be submitted in ACE and sufficient trade testing is completed).
1Also referred to as validations.
(See ITT's Online Archives or 05/02/08 news, 08050205, for BP summary of a letter sent by the TSN to CBP regarding Edit Modification.
See ITT's Online Archives or 05/02/08 news, 08050210, for BP summary of a CBP Edit Modification Update at a Baltimore, MD ACE Seminar.
See ITT's Online Archives or 02/26/08 news, 08022605, for BP summary of TSN trade members saying that CBP had scaled-back its Edit-Lite proposal.
See ITT's Online Archives or 10/05/07 news, 07100505, for BP summary of the TSN Transition Committee responding to CBP's proposal to have minimal edits in ACE.
See ITT's Online Archives or 05/01/08 news, 08050105, for BP summary of CBP's quarterly report to Congress on ACE, which briefly discusses Edit Modification.)