CBP Considers How to Address Original Filer's Lack of Visibility to PSCs
CBP officials state the agency is “exploring its options” on how to address trade concerns that the original ACE entry summary filer is missing out on perhaps important information, when a different filer replaces the original filer’s summary with a Post Summary Correction version, as the original filer does not have visibility to the PSC filing.
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The original filer1 however does receive an Entry Summary Status Notification (UC) message when the first PSC has been filed by another filer authorized by the same importer. A UC message will also be issued if the PSC is rejected.
(But if another PCS is filed by someone new (a third filer), the UC message is sent to the “most recent previous owner” of the entry summary, which would not be the original entry filer. To date, CBP sources have found very few PSCs are submitted by filers other than the original filer; however ACE PSC functionality is still relatively new.)
CBP Costing Out Solutions, Expects to Issue Info on Issue
Sources expect CBP to have some information out on this issue in the next month or so, adding that CBP is costing out solutions and doing outreach with several trade groups to determine the best solution for all parties.
CBP Has Listed Two UC Message Programming Issues
CBP deployed PSC functionality on June 4, 2011, and the formal commencement date was July 25. On July 19 and 21, CBP found two programming problems that needed resolution regarding the UC message.
The first programming issue involved the failure of the PSC to create the UC message. The second problem was found when ACE did not construct the A and Z control records of the UC message correctly. (The control records A, B, Y and Z contain the filer code and port code to properly route the UC message to the most recent previous owner.)
As of early August, these two programming issues were still pending resolution. (See ITT's Online Archives or 08/05/11 news, 11080502, for BP summary of these and other open ACE programming issues.)
(CBP allows an unlimited number of PSCs to be submitted for ACE consumption and antidumping and countervailing (AD/CV) duty entry summaries (types 01 and 03), by the importer’s authorized ACE entry summary filers (as long as the PSC is filed within 270 days of the date of entry and 21 or more days before the scheduled liquidation date, the entry is not under CBP review, etc.).
CBP also passes “ownership” of the “PSC-version” of the existing entry summary to the subsequent (or most recent) PSC filer.
Note that if a PSC is filed by someone other than the original filer, the original filer will not get a courtesy notice of liquidation, extension or suspension via ABI. Only the most recent PSC filer will get these notices. Exceptions include (1) filers under NILS. They will still receive the courtesy notice of liquidation if they have been designated by the importer even if they are not the PSC filer and (2) filers when the importer has filed a CBP Form 4811 naming them as the recipient of the bills, refunds, and liquidation notices.
(Through NILS (National Importer Liquidations), an importer can designate one ABI entry filer to receive all of an importer’s liquidation information (e.g. courtesy notices of liquidation, extension or suspension), regardless of the number of different customs brokers the importer utilizes.)
1Limited ABI query and viewing of limited information is also available.
(See ITT’s Online Archives or 07/20/11 news, 11072007, for BP summary of the ACE PSC FAQs.)
See ITT's Online Archives or 06/08/11 news, 11060837, for BP summary announcing the availability of CBP's PSC User Guide, which is available here.
See ITT's Online Archives or 06/24/11 news, 11062403, for BP summary of CBP announcing that paper form PEAs will no longer be accepted for ACE entry summaries, effective September 22, 2011.
See ITT's Online Archives or 06/24/11 news, 11062420, for BP summary of CBP's formal notice on the National Customs Automation Program test that allows importers to use the ABI to file PSC of certain pre-liquidation ACE entry summaries (ESAR IV).
See ITT's Online Archives or 03/29/11 news, 11032911, for BP summary of CBP's March 2011 version of the ACE FAQ.)