U.S. Customs and Border Protection wants to make filing Air Cargo Advanced Screening (ACAS) data as flexible as possible for freight forwarders.
Officials have consistently stated they don’t intend to require a carrier to re-transmit shipment data from the air waybill submitted by the forwarder to Customs.
Some forwarders are still nervous that CBP will not use the ACAS data they submit to populate the house air waybill information required on the automated manifest filing from the airline, forcing them to supply duplicative data.
In today’s world, a forwarder issues house air waybills spelling out for each customer what is being shipped, how and where it is being shipped, and the services provided. Forwarders typically tender consolidated shipments to airlines and will fold multiple house bills into a master air waybill for the carrier, which in turn uses master bill data to file its manifest to Customs at, or after, liftoff showing the cargo contents and details about the flight.
Once ACAS becomes mandatory, forwarders will have the option of submitting the house air waybill data to CBP, filing to CBP and to the carrier, or transmitting as normal to the carrier and letting the carrier file the advance shipment data to CBP.
The carrier will know that a forwarder has directly submitted house bill data to CBP because those documents will be referenced in CBP’s system with the master bill number. When the carrier files its manifest it will also use the master bill number, which will correlate all the regulatory and security documentation in CBP’s system, explained Michael Ford, vice president of regulatory compliance and quality for BDP International.
Ford is a member of the Commercial Operations Advisory Committee to CBP and active on an air freight subcommittee that is working on the advance data issue.
Forwarders may experience some redundant work during the early stages of the pilot, but that doesn’t mean things will stay that way, trade experts close to the program say. The purpose of the ACAS pilot is to figure out how to implement processes in the most effective manner.
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Ensuring that multiple parties aren’t required to give the same data is something that industry representatives are expected to watch closely as the rulemaking process evolves.
CBP will also have to resolve air carrier concerns that existing regulations hold the carrier responsible for ensuring proper transmission of the manifest. At a June 13 outreach session on ACAS for industry representatives at Delta Air Lines’ headquarters in Atlanta, airline officials stressed they would find it difficult to accept forwarder ACAS submissions on their behalf without regulations spelling out forwarder requirements for filing timely and accurate information, according to meeting notes taken and provided by Airlines for America.
Forwarders at the meeting indicated if carriers are not going to accept their transmissions, it reduces the incentive for them to participate in ACAS.
BDP is one of the earliest forwarders to sign up for ACAS, has passed the system testing stage and is now sending live transmissions of actual shipments from Germany in real time, Ford said. The Philadelphia-based logistics provider wanted to start with a single country while it learns the best way to comply with CBP’s needs, he said. Once BDP has a better grasp of the operational, systems, communications, training and other details necessary to effectively interact with CBP and carriers it will implement ACAS filing in other locations, he said.