CBP Workgroup Proposes 12 Simplified Entry Elements, Updates Summary/Financial

(In August, CBP announced that a Simplified Entry, Summary, & Financial Workgroup, comprised of members from both government and industry, had been tasked to create models for a streamlined entry/entry summary, as well as financial processes. The two-part proposal for “simplified trade processes” resulted from those efforts.)

Release Decision Would Occur 5-10 Days Prior to Arrival for Ocean Mode, Etc.

According to the Workgroup's proposal, in the ocean vessel mode, importers and carriers would transmit their data no later than 24 hours before lading, and would receive a release decision message from CBP approximately 5-10 days prior to arrival.

The simplified entry process model would apply to other modes (e.g. air, truck) with appropriate pre-lading filing and release timelines. In addition, targeting and other security procedures remain the same, but could occur earlier in the process.

Release on 12 Data Elements (Subset of ISF + Add'l Elements)

CBP has previously stated that under Simplified Entry, a reduced list of data elements would be submitted to obtain the release of goods. According to the presentation to COAC, the 12 proposed data elements are:

• HTS 10-digit *
• Estimated total shipment value *
• Entry number *
• Buyer EIN number *
• Shipper name & address *
• Ship to Party name & address
• Country of origin
• Manufacturer/supplier name & address
• Importer of record no.
• Buyer name & address
• Bill of lading/House air waybill +
• Container stuffing location (mode-specific) +

*Elements in addition to the ISF data elements (for the HTS number, the complete 10-digit HTS no is proposed; the ISF is at the 6-digit level).

+ISFs are for the ocean mode only, but simplified entry would include other modes.

CBP Form 3461 Filing would be Eliminated

Under the proposal, advanced manifest filing requirements for carriers would remain the same; however, current CBP Form 3461 entry filing would be eliminated. (According to the TSN, the simplified entry method would serve as both the ISF filing and entry processing.)

(The TSN’s Transition Committee’s Integrated Communications Subcommittee recently stated that the first iteration of simplified entry would be for formal and informal entries only.)

Pilot Qualifications to Include C-TPAT Tier 2 or 3

The presentation indicates that the proposed qualifications for participation in the initial pilot of simplified entry, which would be announced in a Federal Register application notice, are:

• Customs-Trade Partnership Against Terrorism (C-TPAT) Tier 2 and above
• Meets relevant systems requirements

According to a recent TSN press conference and summary, participation would also be limited to importers with continuous bonds and that no Participating Government Agencies (PGAs), or Immediate Transportation (ITs) would be allowed at this time.

Pilot Development to Begin by End of Oct 2011

According to the proposal, the simplified entry pilot¹ development is expected to begin by the end of October 2011 for air and ocean vessel modes.

Simplified Summary and Financial

Under the proposal for Simplified Summary and Financial, periodic summary filing and payment would take place over a two “business month” period as follows:

Business month 1 = entry of goods occurs

Business month 2 = all goods imported in business month 1 are reported for summary and payment.

Other proposed features of the Workgroup’s periodic summary filing and payment proposal include:

• choice of extracting data from business records in order to file the summary, or tracking data by transaction
• summary filing would be due 20 calendar days after the close of the previous month,
• liquidation would occur at the line-level,
• a deemed liquidation would occur within a year, and
• the Reconciliation process would remain unchanged.

Pilot Qualifications Include C-TPAT Tier 2 or 3, ISA or Internal Controls, Etc.

The proposal indicates that the qualifications for participation in the initial pilot of simplified release and financial, which would be announced in a Federal Register application notice, are:

• C-TPAT, Tier 2 and above
• Importer Self Assessment (ISA) or the ability to demonstrate to CBP how the importer will account for imported goods (identification of internal controls and documentation of the information flow through business system to meet summary filing obligations)
• Good financial standing with CBP (to be defined)

Pilot Development to Begin in Jan 2012

The proposal indicates that the next steps for the development of a simplified summary and financial will be the resolution of internal CBP issues. CBP notes that a Federal Register notice is expected to be published in December 2011 and pilot¹ development is scheduled to begin in January 2012.

COAC Draft Recommendations Generally Supportive of CBP’s Efforts

CBP has also posted COAC’s draft recommendations regarding Simplified Entry and Payment (including summary). In its draft recommendations, COAC was generally supportive of CBP’s work to date on simplified entry and payment.

COAC states that it support the “Phase One” prototype using the proposed simplified entry data and suggests that it is important to articulate/gain support for a plan to continue working on additional phases.

COAC also suggests that CBP continue to use of account data/consideration of participation in trusted trader programs to further reduce the requirement for transactional data for release.

COAC also expresses support for allowing the use of business records to create the entry summary.

¹CBP also refers to the pilot as a prototype in several places throughout its presentation.

(See ITT's Online Archives 11100411 for summary of CBP posting of 17 documents for Oct 4 COAC meeting.

See ITT's Online Archives 11100364, for summary of CBP's Broker-Broker Regulatory Revision Workgroup's updated proposal and the COAC subcommittee recommendations (two of the 17 posted documents).

See ITT’s Online Archives 11081505 for summary of CBP fact sheet/presentation on simplified entry from a July 2011 CBP webinar.

See ITT’s Online Archives 11092805 for summary of CBP’s proposal as detailed at the September TSN meeting.

See ITT’s Online Archives 11091618 for summary of October 4, 2011 COAC meeting where simplified entry will also be discussed.)

CBP’s COAC presentation available here

COAC’s draft recommendations available here