CBP Should Address Small Forwarder Concerns Before Finalizing ACAS Rules Proposal, Say Trade Groups
CBP and the Transportation Security Administration should further consult with small and medium-sized forwarders before moving ahead with proposed rules for the Air Cargo Advanced Screening (ACAS) program, said four trade groups in letters to the two agencies. ACAS, now in a pilot phase, has not included in the pilot smaller forwarders "that rely on an extensive network of independent agents at overseas airports" and for whom "the size and scope of their technology infrastructure" is widely varied, the letter said. The groups, which represent "companies that do not own planes but instead arrange for the shipment of goods by air," asked that more work be done to determine how the ACAS program will affect small and medium-sized forwarders before they are brought under its requirements.
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The groups, the Airforwarders Association, the National Customs Brokers & Forwarders Association of America, The International Air Cargo Association and the Express Delivery and Logistics Association, asked that the agencies meet with representatives to discuss various concerns. "Any ACAS rule should maintain the level playing field for all filers. No requirement should create an unfair competitive business advantage for one filer over another," the letter said. CBP has indicated it is close to issuing a proposal for ACAS rules (see 14052802).
The trade associations also said they worried "that ACAS may not take into account variances among U.S. trading partners in the applicability and procedures of their own screening programs, most notably that not all countries of origination allow forwarders to screen cargo," said a joint press release. It's important for ACAS "to clarify what the process and verification procedures will be when an ACAS dual-filing is made at a foreign location, first by the forwarder and then by the carrier," said the letter.
Also of concern are "targeting rule sets" for determining when additional high risk screening will be performed, they said. The groups ask that ACAS use only those risk analysis formulas that have been tested in the pilot. The letter to the TSA also goes into concerns about operational procedures for forwarders' screening of targeted shipments into the U.S., which have also not yet been fully tested, they said. That letter also inquires about "the potential impact for screening of U.S. export shipments when other countries' advance data programs take effect," the release said.
Email ITTNews@warren-news.com for copies of the letters.