U.S. Customs’ five-week postponement of mandatory filing of electronic air import manifests through a new IT system is actually a positive development and reflects well on the agency’s ability to manage the rollout of the Automated Commercial Environment, air industry officials said.
Customs and Border Protection recently notified the trade sector that the scheduled May 1 transition of the automated Air Manifest System from the old, existing system to ACE will not take place until June 6 to allow carriers and freight forwarders to test the system and their middleware that communicates with ACE.
CBP officials said during an April 30 webinar that they were still trying to resolve 30 bugs in the ACE Air Manifest System. Carriers found more issues in their systems than expected, according to industry sources, due to the fact the new system is coded more strictly to the requirements of the air manifest messaging standards than the legacy Automated Commercial System.
The manifest is collected prior to aircraft landing in the United States and automatically screened for security purposes.
The agency will continue to run two systems in parallel—the legacy ACS and ACE for air manifests. Transportation companies will file to the old system and the agency will simply route the data about cargo shipments onboard aircraft to ACE until June 6, when the ACS system for air manifest is scheduled to be phased out.
Air cargo officials said they view CBP’s delay as a good sign because it shows the agency wants to make sure all parties are ready to use the system when it goes live.
In a statement to American Shipper, Airlines for America, the trade group representing the nation’s major passenger and express delivery airlines, praised CBP’s “flexibility and close cooperation with the trade to assure that all stakeholders are ready for the Automated Commercial System Air AMS ‘shut off.’
“Because the air mode of transport depends upon the fast and seamless movement of goods, carrier and system readiness are of utmost importance, and providing carriers sufficient time to complete their necessary testing in the ACE certification environment is key to ensuring a smooth transition,” the group said.
The International Air Transport Association’s cargo division in the Americas said in a statement that CBP recognized the need to address some unique technical challenges associated with the air cargo environment.
“The willingness of CBP to permit air carriers to test for a few additional days in ACE shows the commitment to partnership and the global big picture that will make the system a truly paperless system of the future,” IATA said.
At the April 24 Commercial Operations Advisory Committee meeting, Michael Mullen, executive director of the Express Association of America, stood up and urged CBP to allow adequate time for the private sector to test its systems for at least six weeks as new deadlines come up.
“And that means that the code has to be locked down at some date well before some date like May 1 or Nov. 1 so the trade can engage in very realistic testing with what is going to be the final version of the program,” he added.
Nov. 1 is the date when filing all types of customs entries will switch over from ACS to ACE and become entirely paperless.
Brenda Smith, CBP’s assistant commissioner for international trade, told American Shipper that Customs could have played hardball on the deadline, but thought it was better to follow through on the commitment to facilitate trade.
The three airline groups “did a really low-key job of bringing us the numbers and showing us how their industry was making the transition. And it was not as quickly as we had hoped.
“And I think it speaks to the partnership and the ongoing back-and-forth between the government and the private sector to understand both what business needs and government needs and how we bring those things together,” she said.
CBP officials are engaged in daily conversations with the air cargo associations to make sure everyone is seeing the same information and understands the critical issues that need to be addressed first, Smith added.
The agency will apply that approach with customs brokers as it nears the Nov. 1 deadline, she said.
Although CBP has done extensive outreach to industry, “I think there are metrics we need to be watching: who is testing, who is certified to operate in ACE, how many transactions are we seeing,” she said.
A big focus in the next few months, Smith said, will be making sure trade filers are comfortable transmitting data in ACE for other government agencies under the single-window initiative.
The manifest delay has an indirect impact on customs brokers and importers, explained Elizabeth Connell, vice president of product management at Integration Point, a global trade compliance software company.
Air manifest data is used to fill out special forms to move air freight from the airport to a foreign trade zone under bond without paying duties and companies will now have to wait to realign their processes for the new electronic form (called QP/WP) until June 7.
Also on hold is a new CBP requirement for three extra data elements from the manifest for an in-bond permit to transfer cargo within the same port limit.
Finally, a tool importers use to query CBP’s system for bill of lading information will not be available in ACE. The tool allows companies to make sure that the full quantity within a shipment—cartons for example—is properly recorded and the bill is correctly closed out because any product that CBP does not match up in its records gets sent to general order, Connell said.
Under CBP rules, importers have 15 days to take delivery of goods after arrival at a port of entry or they will be removed to a special warehouse at the importer’s expense. If the goods are not cleared within six months, they are auctioned, donated or disposed of by the government.
This column was published in the June 2015 issue of American Shipper.
