The NCBFAA responded with alarm to Customs and Border Protection’s March 16 mandate to use the new “create/update importer identity form.”
The National Customs Brokers and Forwarders Association of America responded with alarm to Customs and Border Protection when the agency announced Friday its mandate for the use of its new “create/update importer identity form” (CF 5106) by March 16.
Amy Magnus, NCBFAA president, warned CBP officials in a letter Friday that the March 16 deadline “will cause unnecessary hardship for the trade.”
“Adequate time for software development, user testing and user training has not been provided,” Magnus said.
The NCBFAA said it has been repeatedly assured by CBP that customs brokers would have a minimum of 30 days to test the new CF 5106 in their systems.
“Because the programming is only available in certification and the final CATAIR (Customs and Trade Automated Interface Requirements) has not yet been released, brokers have not yet had the opportunity to test or train with the new 5106,” Magnus said.
The association also is concerned about the “hard cutoff” between use of the old CF 5106 and the new one in CBP’s Automated Commercial Environment (ACE).
“NCBFAA, with the support of the software vendor community, requests a soft transition to the new 5106 if at all possible,” Magnus said. “If CBP is unable to provide this soft transition, then we need a more workable solution for a seamless transition from the old form to the new. A two-day gap in total functionality from end of business March 15 until the evening of March 17 or early March 18, as stated on a CBP call, will create difficulties for brokers processing cargo release in a 24/7 environment.”
The NCBFAA also noted a lack of policy documents from the agency regarding the shift to the new CF 5106. Without that, Magnus said the changeover will be “extremely difficult to manage for the brokerage community.”
Tom Gould, chairman of the Trade Support Network’s Trade Leadership Council, backed the NCBFAA concerns. “The lack of testing and training for the trade community is of great concern to the TSN,” he stated in a letter to CBP.
“The software vendor community requires more than nine days to properly program, test and deploy the required changes. It is imperative for CBP to extend the time frame an additional 30 days to allow for the programming and testing in order to ensure accuracy,” Gould said.