CBP Establishes Permanent Pharma & Electronics CEEs w/ AE Concept, Expanding Scope

(CBP launched the pilot CEE for pharmaceuticals in Los Angeles in November 2010 to facilitate trade and manage risk within the industry. CBP also launched the Account Executive (AE) pilot in New York for selected trusted partners in the electronics industry to provide account managers more authority to influence the ports and procedures. Earlier in 2011, CBP officials stated that the agency was considering making the AE pilot a component of the CEE and the two pilots permanent components of CBP. CBP has also recently announced its goal of establishing a total of ten industry breakouts for CEEs.)

(See ITT's Online Archives 11102403 for initial summary of CBP's permanent establishment of these CEEs.)

Changes Include Combining CEE & AE, Expanding Scope, Operational Processing

CBP states that the Centers will continue efforts to increase uniformity of practices across ports of entry, facilitate the timely resolution of trade compliance issues, and further strengthen critical agency knowledge of key industry practices.

In addition to making these Centers permanent, CBP sources state that the agency is making several other changes, including:

• Combining CEE & AE into new Centers. CBP is combining the CEEs with the Account Executive concept into the new Centers.
• Pharma CEE to cover devices, chemicals. CBP is also expanding the scope of the Pharmaceutical Center to also cover health devices and chemicals.
• Electronics CEE to cover IT. The scope of the Electronics Center is also being expanded to include consumer electronics and information technology.
• Operational processing for trusted partners. CBP is beginning operational processing for trusted partners.

Import Docs for Trusted Pharma & Electronics Partners Now Being Routed to Centers

According to CBP, required import documents for Customs-Trade Partnership Against Terrorism (C-TPAT) and Importer Self-Assessment (ISA) trusted partners within the electronics and pharmaceutical industries are now being routed to their respective industry Center. While revenue collection will continue to be carried out at the ports of entry, the Centers will begin to perform all validation activities, protests, post entry amendment (PEA)/post summary correction (PSC) reviews, and prior disclosure validations for the trusted partners within their industry. CBP sources note that this concept was tested on a very limited basis during the pilot.

Routing to Centers Will Free Up Ports, Segment Risk, Deliver Uniformity, Etc.

By redirecting work involving trusted shippers within the electronics and pharmaceutical industries to centralized, industry-specific locations, ports of entry will be able to more effectively focus resources on high-risk shipments and importers that may pose a danger to U.S. border security, harm the health and safety of consumers, or violate U.S. trade laws and intellectual property rights critical to the nation’s economic competitiveness.

In turn, CBP states the approach to trade processing facilitated by the new Centers will reduce transaction costs for the trade community, facilitate legitimate trade through risk segmentation, increase agency expertise and deliver greater transparency and uniformity of action within a given industry.

Centers Are also Resource to Broader Trade Community & U.S. Gov't Partners

The Centers are also a resource to the broader trade community and to CBP’s U.S. government partners; center personnel will answer questions, provide information and develop trade facilitation strategies to address uniformity and compliance concerns. CBP sources hope this capability is strengthened as the Centers become fully staffed.

CBP Has Proposed a Total of 10 Industry Breakouts for Centers

According to documents CBP has provided on its October 4, 2011 COAC¹ meeting, including the recently established Pharmaceutical and Electronic CEEs (denoted with an asterisk *), CBP has proposed a total of ten industry breakouts for CEEs, as follows:

• Agriculture and Prepared Products
• Automotive and Aerospace
• Base Metals and Machinery
• Consumer Products
• Customhouse Brokers
• Industrial and Manufacturing Materials
• Information Technology and Consumer Electronics*
• Petroleum, Natural Gas and Minerals
• Pharmaceuticals, Health and Chemicals*
• Textiles, Wearing Apparel and Footwear

¹Advisory Committee on Commercial Operations of Customs and Border Protection

(See ITT's Online Archives 11061303 for summary of CBP officials stating CBP was considering making the pilots permanent in October 2011.

See ITT's Online Archives 11082411 for summary of the changes CBP anticipated for the pilots after October 2011, which include the creation of 8-10 new CEEs for other industries, removing entry criteria holding up shipments, use of CEEs instead of CF 28s for information, etc.

See ITT’s Online Archives 10102613, for summary announcing the November 2010 commencement of the pilots.

See ITT's Online Archives 11100411 for list of documents provided during the October 4, 2011 COAC meeting.)

Summary of COAC's Trade Facilitation Committee's draft recommendations on the CEEs is available here.