FY 2008 Report to Congress on ITDS

The ITDS concept 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 the Automated Commercial Environment (ACE). Currently, 46 agencies are working together with U.S. Customs and Border Protection (CBP) to implement ITDS.

Status of ITDS Implementation

Highlights of the report's discussion of the status of ITDS implementation include:

Information access through ITDS partly operational. Some functions associated with ITDS are partly operational. ITDS agencies are able to obtain, in near real time, detailed information about imports reported through an electronic filing. Certain information currently required by CBP from importers (entry summary data) is transferred daily from CBP's current processing system to the ACE "Data Warehouse," which ITDS agencies can access through the ACE Portal. Twenty-seven ITDS agencies (511 staff members) currently have access to data on import transactions through the ACE Portal.

Agencies have already been able to put this ITDS information to work. However, a number of agencies currently with ACE Portal access (or that could have Portal access) are probably not taking advantage of it because they have not fully explored ITDS, or because doing so requires changing the way the agency does business.

Other agencies are unable to use the ITDS import information as (1) the data they need have not yet been added to the ACE "Data Warehouse," or (2) the data have been added, but software for retrieving the data has not yet been perfected or has capacity limitations.

CBP explored the addition of all import information currently reported electronically to CBP to the ACE "Data Warehouse," but no action was taken due to cost and the impact on the overall ITDS schedule. However, CBP is exploring making some information available to specific agencies directly from the Automated Commercial System (ACS). This could provide significant immediate value at relatively low cost.

None of the "single window" filing functionality has been implemented. None of the "single-window filing" functionality that eliminates redundant reporting to multiple agencies has yet been implemented. While the ability to collect additional data on behalf of the Federal Motor Carrier Safety Administration (FMCSA) has been built, its implementation is on hold until CBP and FMCSA complete a Memorandum of Understanding (MOU). "Single-window filing" capability for other agencies is only in the very earliest stages of development.

(Single window filing that will give importers, exporters, and carriers the ability to make a single filing for each transaction rather than separate filings for each agency is expected to be available only at the completion of the ACE program in 2011 or beyond.)

Many agencies hope to use ATS to identify risky shipments. A number of agencies hope to make use of CBP's Automated Targeting System (ATS) to review import data and identify risky shipments. Identifying shipments with risks of concern to specific agencies (e.g., contaminated meat, plant or animal pests, or violations of conservation laws) involves developing algorithms that would evaluate data collected through ACE/ITDS.

Agency access is unfiltered during current "test stage." The ACE Portal is intended to have "access filters" to limit users and/or agencies to the particular data in which they are interested. The data exchange architecture intended to provide variable levels of access has not yet been implemented. In the current "test stage," access is available but unfiltered and, as a result, agency users are required to have extensive background checks and security clearances, often of a level beyond that normally required for their positions, for access to the data in which they are interested. Obtaining security clearances for agencies is time-consuming and expensive for ITDS agencies, and it also discourages use of the ACE Portal.

First step in building "single window" is harmonized ITDS Data Set. A critical first step in building a "single-window" filing system is harmonizing agency data requirements. Agencies often define basic information (e.g., value of goods, identity of importer, and origin of goods) in different ways. In order to eliminate redundancies and idiosyncratic definitions, agencies participating in ITDS harmonize their trade data requirements. Data harmonization is a fundamental part of the ITDS Program. Without harmonization, many redundancies cannot be eliminated. Clearly defined data requirements are necessary for determining reporting requirements, developing the reporting input messages through which data is gathered, and also for data storage and delivery to other agencies.

Goal of harmonized ITDS Data Set by January 2008 not met. The 2007 Report to Congress recommended that the ITDS Data Set be established by January 1, 2008; however, that goal was not met. Not only was it an overly optimistic goal, the recent focus on integrating import safety agencies into ITDS diverted resources from data harmonization. The data harmonization effort has been refocused and now includes direct participation by the ITDS Board of Directors, which has accelerated the effort. It is imperative that this work remain the primary focus of all involved in ITDS.

ITDS Board of Directors recommends acceptance of DUNS numbers. Several Federal agencies require traders to identify themselves or the people with whom they are trading by using agency-created and maintained identification numbers.

The ITDS Board of Directors believes many of the problems surrounding multiple identifiers could be addressed by utilizing the DUNS Number (Dun and Bradstreet Universal Numbering System) to identify parties reported through ACE/ITDS. The DUNS Number system has wide coverage in many parts of the world, and significant resources are invested in keeping the DUNS database updated. The WCO recognizes the DUNS Number as an acceptable identifier in its WCO Customs Data Model and the DUNS claims to be ready to assign numbers to any business or organization in most of the world.

In late 2006, the ITDS Board of Directors unanimously recommended that CBP and the other participating government agencies (PGAs) accept the DUNS Number as an alternative to identify parties in all ACE transactions and that CBP build that capability into ACE. In response to the ITDS Board of Directors' recommendation, CBP agreed that the DUNS Number is a valuable tool for identifying companies, explained immediate plans to use it as a secondary identifier, and announced plans to use the DUNS Number more extensively in future ACE releases.

However, CBP may be reconsidering its plans to utilize the DUNS Number. The ITDS Board of Directors continues to recommend use of the DUNS Number in order to reduce the reporting burden on traders and obtain more accurate and complete identification of parties to international trade transactions.

Use of product codes, instead of tariff numbers, being explored. A number of agencies require traders to provide a product code in order to identify or categorize imported products in a way that is machine readable and consistent with their regulatory functions (the tariff system is inadequate for many agencies' purposes). The goal is to efficiently identify essential characteristics of imported products for the purposes of determining admissibility and for reporting with greater accuracy on the nature of products moving across U.S. borders. ACE/ITDS is building an inventory of the product codes that agencies want to collect.

Consistent with the ITDS Data Harmonization effort, ITDS agencies are exploring opportunities to use the same product codes whenever possible. This would reduce the burden on traders of reporting two codes for the same product and also reduce the burden on the government of maintaining multiple code systems. ITDS agencies are considering using international product "dictionaries" used by business as the basis for the product codes they will require to be reported by importers.

ITDS report to Congress (dated 10/08) available at http://www.itds.gov/linkhandler/itds/toolbox/library/resource_documents/itds_congress.ctt/itds_congress.pdf