CBP postpones July 8 rollout of drawback entry filing
Everything you used to know about filing a drawback claim is changing.
For 228 years the trade has collected data elements and transmitted them on paper drawback claims to the government for their approval and payment.
Gone are the days of two-foot long parchment paper claims from the 19th Century that captured the vessel and vessel master’s name, along with the duty paid, the payee, and the date the ship left the country. Drawback claimants of the future will look back on the early 21st Century and see that the drawback claims that we filed were not so different from those parchment paper claims from two centuries ago, with similar claim contents transmitted via paper folders through the mail.
U.S. Customs & Border Protection (CBP) announced Tuesday, through its Cargo Systems Messaging Service (CSMS) that Deployment G for the Automated Commercial Environment (ACE), which includes drawback, collections and statements, reconciliation and liquidation has been delayed until further notice. The update was to have gone into effect July 8.
In a notice published on its website Tuesday, CBP said it “is rescheduling the last primary deployment of core trade processing capabilities in ACE which had been scheduled for July 8, 2017. This deployment includes liquidation (with the exception of the previously deployed electronic posting of the Notices of Liquidation on CBP.gov), reconciliation, drawback, duty deferral, collections and the Automated Surety Interface (ASI). The rescheduled deployment date will be published at least 30 days in advance of the mandatory transition.”
This follows delays with earlier suggested release dates of Oct. 1, Oct. 29, and Jan. 14. We’re hoping to have drawback in ACE by the end of the year to allow us to work through the kinks before testing is required for drawback under the Trade Facilitation and Trade Enforcement Act in early 2018.
The trade processing capabilities are the core elements that will allow you to transmit your drawback claim, similar to what is processed today. Below is a sampling of the large changes for a transmission of a drawback claim to ACE that everyone in the trade should know:
• The consolidation of drawback to entry type 47; entry types 41-46 will no longer exist. The specific types of drawback for unused merchandise versus manufacturing drawback, for example, will be still be identified in the transmission to ACE, but will not have their own entry type.
• All of the data elements of a drawback claim are to be submitted electronically. This now includes full import elements, export data, and bill of material information for manufacturing claims.
• Previous transmissions through the Automated Broker Interface (ABI) included specific data validations against import data elements only. The validations in ACE incorporate checks for all transmitted data. The trade can receive “Fatal” or “Informational” messages with each claim submission (for detail on the specific messages, review the CATAIR from CBP and Trade Automated Interface Requirements April 2017).
• There is a 5,000-line limit each for import, export and bill of material data. ACE has limitations for the sizes of the files it can receive for drawback claims, and the 5,000 line maximum is a function of that limit.
• Manual paper claims can still be filed if you’re not ready to file in ACE. If you decide to file a manual claim, your submission is limited to 25 cumulative data elements. Drawback specialists who receive manual claims will need to manually enter data into the system to process the claim, and because of that, there will be an approximate 90-day delay in processing for accelerated payment (if the claimant has the privilege).
• Data elements for the transition to drawback under the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA) will be released for testing at a later date yet to be determined. This deployment allows for today’s drawback in an electronic environment.
• Each drawback claim will have to follow the guidelines and policies of CBP. A trade document has been completed by CBP for all ACE functionality, with Section 18 dedicated to drawback. Reviewing this document is essential for anyone filing a drawback claim (Business Rules and Process Document v. 8.0).
Discussion of the changes to filing drawback claims was a major topic at the American Association of Exporters and Importers’ annual conference in Austin last week. CBP Acting Commissioner Kevin McAleenan noted it as an agency priority during a keynote speech at the conference, and several panels touched on how the changes might impact broker and shipper entries in ACE.
As we move forward with the technology that the trade has been waiting for, we brace ourselves for a time of transition. We look forward to the simplicity of the process, a reduction of paper, and a drawback claim process in the future that will be more efficient. Simple or not, and whether you like it or not, ACE will be the place to file your drawback claims.
author:
Dave Corn