INDUSTRY COALITION SUBMITS ENTRY REFORM WHITE PAPER TO CUSTOMS

INDUSTRY COALITION SUBMITS ENTRY REFORM WHITE PAPER TO CUSTOMS    After two months of intense work, the U.S. import industry has crafted and submitted to Customs a broad consensus position to reform the country’s import entry process.
   A trade coalition of 17 industry groups, representing a range industry sectors such as apparel, electronics, automobiles, sureties, air carriers, and attorneys, agreed to draft a “white paper” to Customs during an industry-only Entry Revision Project meeting in Washington last month.
   Serving on the drafting group were the U.S. Business Alliance for Customs Modernization’s Dick Abbey, Richard Belanger of the Joint Industry Group, Harvey Isaacs of the National Customs Brokers and Forwarders Association of America, and John Simpson from the American Association of Exporters and Importers.
   All 17 groups of the trade coalition signed off on the white paper on Monday. “This is an unprecedented accomplishment for the U.S. trading industry on the U.S. Customs entry reform initiative,” said James P. Finnegan, director of international trade and compliance for Sony Electronics and chairman of the U.S. Business Alliance for Customs Modernization.
   The white paper covers six key aspects of the import entry process which need reform:
   * Cargo release and entry tracks: The industry wants “minimal data at release” for all importers on formal entries. To support this aspect, a Treasury study on the necessary data elements to clear imports will be submitted to Congress in May.
   * Importer Activity Summary Statement: The industry supports the filing of the IASS 20 (or 10 days proposed by the Census Bureau) after the end of the reference month. A test of the IASS is already planned for land-border shipments.
   * Post release and revisions: The industry supports a modernized version of Customs’ post entry amendment and reconciliation programs to “revise” entry data. Customs has been asked to support an amendment to its rules that allow for a period not more than 21 months from the beginning of the importer’s fiscal year to file reconciliation entries.
   * Money: The industry has asked Customs to support several payment approaches to settle duties, taxes and fees on imports. The three options are the current 10-day payment period, payment against a daily statement, and a system using periodic estimated payments of duties, taxes and fees.
   * Protests: The industry favors the ability to protest entries before final liquidation to recover any overpayment of duties.
   * Drawback: With the IASS in place and modernization of the current drawback law, drawback claims should be easier to file and claim from Customs.
   “I believe the trade industry document is a reasonable and practical framing of the general principles for customs entry reform, and serves as an excellent departure point for the next step in the process — the detailed work of developing functional specifications that will be used for ACE (Automated Commercial Environment) system design,” Finnegan said.
   Customs received a hand-delivered copy of the white paper Tuesday morning. The trade coalition’s management team of nine industry executives will meet with Customs officials in a two-hour meeting today to “walk” them through the document and to consider the next steps in carrying out the import entry reform process