CBP Lists Trade's Strategic Ideas, Continues to Accept Comments
U.S. Customs and Border Protection has listed the types of suggestions it received from the trade community on the 2009-2013 Trade Strategy CBP discussed at the April 2011 Trade Symposium. Eliminating textiles as a Priority Trade Issue (PTI); communicating realistic timelines for shared projects such as ACE; focusing on port consistency; and capturing subject matter expertise at the right locations, were some of the types of suggestions made.
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(CBP first presented its Trade Strategy for FYs 2009-2013 at the 2008 Trade Symposium. At the April 2011 Trade Symposium, CBP provided an overview of the Trade Strategy’s four goals and the actions it is taking to meet them.
The four goals of CBP’s FY 2009-2013 Trade Strategy are: facilitate legitimate trade and ensure compliance, enforce trade laws and collect accurate revenue, advance national and economic security, and intensify modernization of CBP’s trade processes.)
CBP Received Feedback on PTIs, Modernization, Uniformity of Enforcement, Etc.
At the April 2011 Trade Symposium, a CBP official stated that CBP was seeking comments and suggestions regarding its trade strategy and an email address for the public to submit its comments and suggestions was created. (See ITT’s Online Archives or 04/21/11 news, 11042117, for BP summary of the discussion of CBP’s Trade Strategy at the April 2011 Trade Symposium.)
According to CBP, the feedback it received from the trade community at the CBP Trade Symposium on the strategy fell primarily into the following 7 areas:
Outreach
- Communicate realistic timelines for shared projects (ACE)
- Reach out to small/medium businesses
- Keep National Account Managers a priority to assist communication efforts
- CBP and the Trade need to find efficiencies together
- CBP website needs to be redesigned to be more user-friendly
Priority Trade Issues (PTIs)
- Revise and update as needed
- Remove textiles as PTI (textiles emphasis out of sync with industry today (e.g. no quotas); this PTI can be placed in other areas, such as Revenue)
- New Trade Agreements PTI established
Other Government Agencies
- Work on shared issues (AD/CVD retroactive system (burdensome to trade and creates uncertainty for business community and companies do not know who to call when they have issues; hopes to expand CBP partnerships to OGAs)
Modernization
- Work towards progress on ITDS/ACE
- Critical if account-based management is a true priority
- Single Window is needed
- Streamline the process, provide consistency so small actors can comply
- Beyond ACE, incorporate innovative automation methods that work to facilitate trade
- Align 9-5 client rep support to 24/7 Trade practices
Partnerships
- Keep evolving risk management processes (to rule out certain importers)
- Programs are worthy and should be expanded (e.g. Account Executive and Centers for Excellence and Expertise)
Human Capital
- Capture subject matter expertise (SME) knowledge in the right locations, ensuring the ports have the expertise they need for enforcement efforts (outreach to SMEs has been challenging to non-existent; adequate staff-levels at ports to address trade concerns)
Uniformity of Enforcement
- Ensure PTIs matriculate to the field and are uniformly implemented
- Port consistency should be a focus
- Clarify material/immaterial errors
CBP Still Taking Comments and Suggestions
CBP states that it is still taking trade community comments and suggestions on the CBP
Trade Strategy at cbptradestrategy@dhs.gov.