NMFS Issues ANPR on Electronic Filing of Trade Documents via ACE/ITDS
The National Marine Fisheries Service has issued an advance notice of proposed rulemaking to announce that it is revising the procedures for filing import and export documentation for certain fishery products to meet requirements of the SAFE Port Act of
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!
- 61, etc.
Specifically, NMFS intends to integrate the collection of trade documentation within the International Trade Data System and require electronic information collection through U.S. Customs and Border Protection's Automated Commercial Environment.2
NMFS Seeks Input on Feasibility of Electronic Reporting, Development of Electronic Info Collection Procedures
NMFS is seeking advance public input on the feasibility of electronic reporting by parties involved in an import or export transaction for applicable seafood products and on the development of electronic information collection procedures for the purposes of determining which shipments of seafood products are eligible for entry into the U.S. Comments are due by August 6, 2009.
Specifically, NMFS is seeking input from the public on the following (partial list):
CBP systems. What CBP electronic reporting systems does your business use (e.g., Automated Commercial System, Automated Broker Interface, etc.)?
ACE account. Does your business (importer, customs broker, shipper, carrier) currently maintain an ACE portal user account?
Blanket permit required. As an importer, how would your business be affected if you are required to obtain a blanket permit (e.g., annual) prior to importing your product?
Limited ports for imports. How would your business practices be affected if NMFS required imports only through a limited number of designated ports of entry?
Problems with paper reporting. What problems, if any, have you encountered with the existing paper document systems for NMFS trade monitoring programs? Could these problems be resolved by electronic reporting?
Timely release. What concerns do you have about timely release of perishable seafood shipments? In your view, could electronic reporting expedite the submission of information to CBP to obtain release? How would your business be affected if information collection requirements cause a delay in release of shipments?
Pre-approval. How would your business be affected if NMFS required pre-approval for all inbound seafood shipments that are subject to documentation requirements?
NMFS Currently Reconciles Paper Data with CBP Electronic Information
As a result of unilateral authorities and/or multilateral agreements, NMFS has implemented a number of monitoring programs3 to collect information from the trade regarding the origin of certain fishery products. Generally, these trade monitoring programs require importers to obtain a blanket permit, to obtain from exporters documentation on the authorization for the harvest by the flag nation, and to submit this information to NMFS for review and approval.
In most cases, these monitoring programs require the importer to provide paper documents to NMFS, while other relevant information on the inbound shipments is provided to CBP by electronic means. NMFS reconciles the information reported by importers with the information obtained from CBP to determine if the admissibility requirements have been satisfied.
NMFS Already Receiving Benefits as an ITDS/ACE PGA
NMFS notes that as a participating government agency, access to the ACE portal has improved its ability to evaluate trends and potential problems with seafood imports. NMFS anticipates that ITDS integration will result in reduced reporting burden for the trade community, reduced data processing time for government, increased compliance with product admissibility requirements, and quicker response time on admissibility decisions.
1The Security and Accountability for Every Port Act of 2006 (Public Law 109-347) requires all Federal agencies with a role in admissibility decisions for imports to collect information electronically through ITDS.
2ITDS 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 ACE.
3NMFS trade monitoring programs cover tunas, swordfish, billfish, shark fins, toothfish, krill and certain other fishery products.
NMFS contact- Christopher Rogers (301) 713-9090
NMFS ANPR (D/N 090223227-9691-01, FR Pub 05/08/09) available at http://edocket.access.gpo.gov/2009/pdf/E9-10820.pdf