ITDS Annual Report Examines Low ITDS Funding, Savings by Use of DUNS, UPCs
The ITDS Board has submitted its annual report on the International Trade Data System to Congress, as required by the 2006 SAFE Port Act.1 The report includes updates on the status of ITDS implementation and the status of the Automated Commercial Environment within U.S. Customs and Border Protection, among other issues.
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(ITDS, which is a part of ACE, is an interagency effort to eliminate redundant reporting by creating a "single-window" system, replacing multiple filings (often on paper) with a single electronic filing. Relevant data would be distributed electronically to the appropriate participating government agencies (PGAs), providing them with the ability to process that data electronically.)
Highlights of the report relating to budgetary and importer and product identification issues include the following (see future issues of ITT for further details on the report):
Contract Funds to Focus on Functionality, Not Planning
The report states that projected funding levels will not support past levels of contractor support (PGA education, high-level business requirements) for ITDS. CBP has decided to focus contract funds on implementing functionality rather than on ITDS planning. Consequently, there will be little to no support for participating agencies' ITDS development work in fiscal year 2010. Work on other agencies' requirements for which funds have not yet been allocated has been halted.
Insufficient funds. In addition, it has become clear that the ITDS Program budget will not be sufficient to fund development of all the "shared requirements" envisioned by participating agencies.
(ITDS Program funding levels for FY 2009 have been adequate to fund the work of the ITDS Project team (now suspended) and the development of ITDS requirements for the ACE Cargo, Control, and Release (CCR) M1 deployment. Funds were also used for training material for the Entry Summary, Accounts, and Revenue (ESAR) A2 release pertaining to entry summary and the Antidumping/Countervailing (AD/CVD) Case Management database within ACE, which is on schedule to be deployed in January 2010.)
Use of Commercial Importer & Product ID Systems Could Trim Costs, Etc.
Several Federal agencies require traders to identify themselves or the people with whom they are trading by using agency-created identification numbers. Due to these different agency requirements, an importer may be required to report several different identification numbers, one for each entity that is involved in the transaction. Government-created identification systems have had problems with duplicate or inactive numbers and out of date information.
DUNS for importer identification. Many of these problems could be mitigated by utilizing commercially maintained systems for identifying businesses, such as the DUNS Number (Dun and Bradstreet Universal Numbering System). The DUNS System has wide coverage in many parts of the world, and significant resources are invested in keeping the DUNS database updated. The World Customs Organization recognizes the DUNS Number as an acceptable identifier in its WCO Customs Data Model and DUNS claims to be ready to assign numbers to any business or organization in most of the world.
The DUNS Number system is already used to identify parties for other U.S. government functions (for example government procurement) and provides other distinct advantages. There is one unique number for each physical location or business division, which is particularly useful for security and safety concerns. The DUNS Number itself is in the public domain so privacy issues are mitigated and DUNS also registers new traders at no cost. DUNS links current firms to closed or merged firms, which helps limit evasion of tax or other legal responsibilities by those who might try to assume multiple identities and maintains "crosswalks" or links to other numbering systems. In 2006, the ITDS Board of Directors recommended that CBP and the other participating government agencies accept the DUNS Number as an alternative identifier for ACE transactions.
UPC for product classification codes. Another area with potential for reducing costs involves the standardization of product identification and classification codes. Several agencies require traders to provide a product classification code, in addition to a tariff number, in order to categorize imported products more precisely (tariff codes are inadequate for many agencies purposes particularly those related to purity and safety).
ITDS agencies are exploring opportunities to use international product classification codes so that traders would not be required to report multiple codes for the same product, which would also reduce the cost to the government of maintaining multiple code systems.
The identification of specific products using a globally unique product number known as the Global Trade Item Number (GTIN) also has cost saving potential. Because a GTIN (also known as the Universal Product Code (UPC)), can be linked to details about the individual product, one GTIN number may be all a trade need report, rather than requiring traders to report several data elements in order to adequately describe a product.
1The "Security and Accountability for Every Port Act of 2006" (P.L. 109-347)
(See ITT's Online Archives or 11/06/09 news, 09110605, for ITT's first summary of this report, which covers the recommendation to have basic ITDS functions implemented using ABI. See future issues of ITT for further details on the report.)
Report to Congress on the International Trade Data System (dated September 2009) available at http://www.itds.gov/xp/itds/whats_new/