CBP Officials Provide an Update on its ITDS ConOps

(CESAC is a voluntary, open, transportation industry forum that provides an environment for the exchange of ideas and the resolution of technical issues. CESAC’s membership is made up of representatives from all modes of transportation (air, ocean, rail and truck), trade sectors, non-vessel operating common carriers (NVOCCs), and any government agencies wishing to participate.)

CBP’s ConOps on Future ACE Interagency Cargo and PGA Processing

CBP defines a ConOps as a high level description of business processes and needs, and as the basic building block of information technology projects. CBP’s ITDS ConOps documents the future vision of ACE CBP interagency cargo processing from beginning to end, including manifest, entry, and post entry operations.

It also demonstrates CBP’s commitment to the “single window concept” for the international trade community, and how CBP and Participating Government Agency (PGA) processes are interrelated.

(CBP’s previous ConOps (prepared in 2004) only looked at CBP’s processes, without including PGA processes.)

Significant ACE Cargo Process Changes Identified for Manifest and Conveyance

CBP identifies the following as significant cargo process changes for manifest and conveyance that it expects to be delivered in ACE in the future:

M1 as model for all modes.Processes for all modes of transport modeled on e-Manifest: Ocean and Rail (M1) functions and business rules.

PGA holds.Process for placing and removing PGA holds on manifest and conveyance.

Electronic notice of arrival.ACE will accept electronic notice of conveyance arrival.

Port Change processes.Change of filer code with retention of manifest and entry data and would require a broker to have national broker permit.

Expedited entry.Recognition of an expedited entry process.

Significant ACE Cargo Process Changes Identified for Entry/Release

CBP identifies the following as significant cargo process changes for entry and release that it expects to be delivered in ACE in the future:

HTS flags.Critical HTS flags will be maintained by PGAs.

Single release, status notifications.Release may be contingent upon multiple agencies but CBP retains “final release” authority; status notifications of agencies holding merchandise and agencies that will have further interest after CBP release will be sent by ACE to the trade; trade community receives one ACE release notification; and carrier and broker are notified of release at the same time.

ISSUE (new terminology). PGAs without release authority may set an ISSUE that notifies the trade that further government review required, such as an examination; and trade interacts directly with PGAs, unless CBP acts on behalf of a PGA.

Release to PGA with ISSUE.Status notifications to notify the broker of government agencies involved beyond release and a final status notification will be sent when all agency requirements have been met.

Transfer of custody/liability.Transfer obligates importer or broker bond; further tracking mechanism for agencies that do not effect release, such as FSIS; offsite examination locations will have FIRMS codes; the transfer will be arrived by the facility that accepts the merchandise; and PGA will acknowledge receipt at facility.

Automated entry correction/deletion.Automated entry correction/deletion process is correlated with entry summary processing.

Significant ACE Cargo Process Changes Identified for Post Release

CBP identifies the following as significant cargo process changes for post release that it expects to be delivered in ACE in the future:

Automation of PGA re-delivery process.Automation of the PGA re-delivery process to track merchandise refused entry. The assumption is that PGAs will need to use ACE for the redelivery process to preserve obligation on the importer’s bond.

PGA requests.PGAs may send requests for information and receive the responses from the filer/importer through ACE.

CBP Was to Deliver Final Documentation and Analysis at End of July

CBP has been working on “Phase 2” of the ConOps. According to CBP sources, this involved CBP doing a “reality check” to see if CBP’s ConOps matched up with those of the other agencies and to make sure that they accounted for everything.

(Six PGAs were mapped to CBP’s ConOps to verify the applicability of processes and document discovered gaps: APHIS, NMFS, EPA, FSIS, FDA, and the Coast Guard).

According to CBP, final documentation and analysis were due at the end of July 2010.

(See ITT’s Online Archives or 06/16/10 news, 10061655, for BP summary announcing that CBP was trying to make its ConOps available to the trade, etc.

See ITT’s Online Archives or 04/20/10 news, 10042026, for BP summary of CBP discussing its own ITDS ConOps.

See ITT’s Online Archives or 03/24/10 news, 10032410, for BP summary announcing that CBP completed Phase 1 of its ConOps.)