The panelists will provide an overview of the key points of the BTB Action Plan, focusing in particular on the initiatives that will benefit the trade. Topics covered will include:

• Which key action items will directly affect the trade such as harmonization of advance trade data and trusted trader programs
• What key opportunities are available to the trade through the BTB Action Plan
• Why  it is important that the trade be engaged in this process now
• What are the US and Canadian Government responsibilities with this plan
• How the trade can start preparing today for the changes this BTB Action Plan will bring
• What key questions you should be asking now regarding the BTB Action Plan

It’s not too late to register for this 90-minute webcast full of information on the Beyond the Border Action Plan.  Register now to learn more about the BTB Action Plan.

And, there is a new resources page available for more information about the Beyond the Border Action Plan.   Access the BTB Action Plan resources.

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Integration Point is working closely with CBP on the QX/WX functionality testing.  We will provide updates on this functionality and the deployment as we receive them.

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Shortly after the NPRM was issued, CBP also initiated the transition of QP/WP to the Automated Commercial Environment or ACE.   This transition took place due to the planned decommission of the Automated Manifest System or AMS, and to meet the proposed changes around the In-Bond process.   Before the transition to ACE, importers had to file the required In-Bond data through the Automated Broker Interface (ABI) into ACS, CBP’s legacy Automated Customs Environment.

Finally in mid-March at the ACE Technical Conference, a clarification by CBP on when QP can be used was made.  According to CBP, QP can be used exports out of an FTZ done via air mode of transport without a truck initiation of the move.  So while QP can be used for all exports, regardless of mode of transportation, CBP did provide the following suggestion for FTZs processing In-Bonds exported via air.

If you are using air to move good In-Bond, you will still provide a Bill of Lading number, however, you will not use the air carriers SCAC code and airway bill number.  Instead, FTZs are to use the FIRMS code as the SCAC and a sequence number as the Bill of Lading number.  You can use the In-Bond number as the Bill of Lading number, since that will guarantee a unique sequence number on each QP.

CBP is continuing to make updates to ACE, and once the comment period is over for the proposed changes to the In-Bond process, we are sure to see more changes there as well.  Plus, CBP recently announced that it plans to roll-out an improved electronic In-Bond filing for importing via air (also known as QX/WX) in May.

The last few months have been an interesting ride, but you can bet that more changes and updates are on the way.

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Called “Trade Benefits from the Automated Commercial Environment,” this document outlines the benefits to the trade in the following areas:

• ACE Secure Data Portal
• Periodic Monthly Statement
• ACE Reports
• Entry Summary Filing
• Post Summary Corrections
• E-Manifest for Truck
• E-Manifest for Rail & Sea

Under each section, CBP details out benefits for the different parties – importers, brokers, self-filers, truck carriers, rail carriers, sea carriers, Trade Account Owners (TAOs), sureties, and all users with portal accounts.

For those not familiar with ACE, according to this document, the “Automated Commercial Environment (ACE) is the commercial trade processing system being developed by the U.S. Customs and Border Protection (CBP) to become the “single window” through which international traders will electronically provide all information needed by federal agencies for the import of cargo. ACE is the enabler of further collaboration between the U.S. Government and the trade community to enhance the security, safety, compliance and flow of international trade.”

You can see the full document here.

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According to Liz, when filing a 7512, you do not have to break out product detail into individual components.   The zone operator can bond the entire shipment, and all the value that is associated with it, since at the time, FIFO has not run and the zone operator has no way to know what is domestic and what is foreign.  Also, because the required data for the 7512 is at such a high level, there is no requirement to show details at the unit level.   When, and if, CBP decides to view the merchandise that is being exported in that shipment, they also do not look at the status of the goods.  CBP is only concerned that you have asked permission to export the shipment as a whole and that the shipment as a whole meets the necessary requirements.   In the inventory control recordkeeping system (ICRS), duty will only be saved on the foreign portion of the goods.

If you have more questions or comments about the process of exporting co-mingled shipments from an FTZ, please post them here.

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With this automated GSP refund process completed, “ports of entry are currently working with the written requests for refunds, as well as those entry summaries which failed the automated refund process.”   CBP is asking importers to review their records to identify those entries for which a refund is due but has yet to be received or is not received by March 30, 2012.   To claim the refund for these entries, importers should notify the port of entry in writing and include the entry number(s), line number(s) eligible for GSP, and the expected duty refund amount.   According to the CSMS, a post entry amendment or protest is not required.

Refund requests must be received by CBP no later than April 18, 2012.  For the full text and instructions for the GSP refund process, click here.

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• 2012 HTSUS Updates
• BIS 2011 Report
• Bonded Warehouses
• Countervailing Duty
• C-TPAT Seal Clarification
• Customs Budget
• Customs Penalties
• Export Best Practices
• Late ISF Importer Report
• QP In-Bonds
• Simplified Entry
• Trade Management
• CBP’s Proposed Changes to In-Bond Regulations
• Enforcement Date Set for KORUS
• Trans-Pacific Partnership (TPP) Negotiations

To read the full newsletter, click here.

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During the ACE Conference in Washington, DC, on March 6 – 7, 2012, CBP clarified that QP can be used for all exports, regardless of mode of transportation.   If you are using air to move goods In-Bond, you will still provide a Bill of Lading number however, you will not use the air carriers SCAC and airway bill number.  Instead, FTZs are to use the FIRMS code as the SCAC and a sequence number as the Bill of Lading number.  You can use the In-Bond number as the Bill of Lading number, since that will guarantee a unique sequence number on each QP.

In other news, we also learned that CBP plans to roll-out an improved QX/WX in May 2012.  Integration Point will be following this and the continuing updates to ACE and QP/WP over the next few months.  Stay tuned for more information.

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#1 – Compliance Education — The entire company should be involved in compliance.  Everyone has a role, and the support of a team can assist the zone operator in meeting compliance requirements while increasing efficiency.

#2 – Training – While this seems like a no-brainer, many companies think if they train one person then they are covered.  In today’s economy, companies try to do more with less.  But when it comes to compliance, sometimes more people being trained on compliance processes is better, especially when operating a zone.  When conducting compliance training, be sure to include the FTZ operator as well as their back-up in all aspects of compliance.

#3 – Self-Assessment – Once compliance is achieved, it takes work to maintain it.  Zone operators should be constantly performing self-audits on all processes as well as reevaluating procedures to ensure compliance as well as efficiency.

#4 – Communication – As the business changes, the warehouse demands change.  Making sure everyone, from accounting to transportation to sourcing, communicates these changes and their possible impact to the FTZ operator is key to maintaining compliance.

#5 – Inventory Controls – Many companies find an FTZ enhances inventory controls.  This is important for compliance as well as cost control since adjustments can increase costs.

Is your FTZ compliant?  Consider how many of these keys you currently have in place, and if you are missing some, you may want to consider how to implement these to improve your FTZ compliance.  Also, if you are considering participation in a zone, check out this on-demand webcast featuring Dom Gambardella with PricewaterhouseCoopers on the ABCs of FTZs.

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First let’s discuss where QX/WX stands.  During the National Association of Foreign-Trade Zones (NAFTZ) Annual Legislative Seminar in early February 2012, CBP representatives stated that there is not a firm date for the re-launch of QX/WX.  CBP wants to wait until the roll-out of ACE M1 is fully completed, with all vessel and rail manifests destined for all US ports being filed in ACE, before it begins looking at a date for the QX/WX roll out.

So, can an inbound air shipment be moved to an FTZ without a QX/WX?  To start, let’s begin with a hypothetical situation– your company operates a zone is in Memphis, Tennessee, and a shipment arrives by air in Atlanta, Georgia and needs to be moved to the Memphis zone.  Can this shipment be moved to the zone in Memphis via QP (current electronic In-Bond filing functionality) or does the In-Bond movement have to be filed using paper?  Because this shipment was initiated by air, the QP electronic filing will not work.  A paper 7512 must be used to move the goods In-Bond to their final destination.   Currently, on any inbound air shipment that need s to move In-Bond through the United States, there is not electronic method to file the In-Bond; therefore a paper 7512 must be completed and submitted.

So, what happens if you have goods moving In-Bond out of that same FTZ?  The goods are going to be trucked from your port to another port where they will be exported by air.   For this type of movement, you would create a bill of landing, including the FIRMS code of the exporting zone as the SCAC,  that would be used for the entire export process.  QP/WP can be filed for the In-Bond movement of the goods, as the filing would create the bill of lading in CBP’s system, and the move would post against that bill.

Integration Point will be staying in close touch with CBP to see when testing for the updated QX/WX may start and when the planned roll-out will begin.   Stayed tuned for more news.

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