Beyond the Border and Trade Facilitation€¦ · Frontline. magazine! Simplified Entry Matthew...

Beyond the Border and Trade Facilitation

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Jim Phillips, Senior Customs ManagerGeneral Motors

Maria Luisa O’ConnellSenior Advisor for Trade Relations and Public EngagementExecutive Director for the Office of Trade RelationsUS Customs and Border Protection

Susie Hoeger, Director Global Trade Compliance & PolicyAbbott

Matt Varner, Director US Trade OperationsNike

Agenda

1. Introduction – Jim Phillips

2. Trade Facilitation Projects – Maria Luisa O’Connell

3. CBP Industry Centers of Excellence & Expertise (CEE’s) –Susie Hoeger

4. Simplified Processes – Matt Varner

5. Questions and Answers

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AAEI Customs Committee

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Excellent Participation By Highly Skilled ProfessionalsStrong Support From AAEI StaffMonthly Meetings/Conference Call• Legislation• Federal Register Notices• Issues and Projects• Events

CBP Industry Centers of Excellence & Expertise

Susie HoegerDirector, Global Trade Compliance & Policy, Abbott

AAEI Annual ConferenceJune 2012

Agenda

“Management by Account” overviewCEE Pilot (and industry’s part)Current CEE OperationsCEE BenefitsNext Steps

Special thanks to Leon Hayward of CBP for letting me borrow some of his slides.


Management by Account (MBA) Initiative

Changing the way CBP does business, pursuant to recommendations made by COACFocus on accounts rather than transactions, and manage risk accordinglyMBA projects included:• Centers of Excellence & Expertise• Account Executive Program• Risk-Based Account Management• Single Partnership Program• Simplified Entry Process• Simplified Financial Processing

Common Goal:Refocus, Reassess, Rethink


“Spectrum of Traders”

High Risk• Enforce• Discourage• Gain

compliance or stop

Unknown• Intervene to

ascertain risk level

• Build compliance or stop

Generally Compliant

• Less interaction

• Trust, but verify

Trusted• Account

manager• Facilitation

Most Trusted• Account

executive team

• “Gold Key”

BULK OF CBP RESOURCES

BULK OF INCENTIVES

Transactional Interaction Account Interaction

ISAmembers


Centers of Excellence and Expertise (CEE)

Pharmaceutical industry chosen for the CEE pilot• Pilot launched Nov 1, 2010

Goals of pilot: • Increase industry-based knowledge within CBP• Facilitate legitimate trade via effective risk segmentation• Enhance enforcement and address industry risks

Active solicitation of input from the trade during pilotTwo CEEs formally established on Oct 1, 2011• Pharmaceuticals (New York)• Electronics (Los Angeles)


CEE 101: How it Works

Bring all of CBP’s trade expertise to bear on a single industry, in a strategic locationIncrease industry-based knowledge to segment risk, develop trade facilitation strategies, and enhance enforcementUtilize multidiscipline teams that employ account-based principles to authoritatively facilitate tradeServe as a resource to the broader trade community and to CBP’s U.S. government partnersServe as a single point of processing for businesses enrolled in CBP’s trusted partner programs (C-TPAT and ISA)


Achieving Pilot Goals:Increase Industry-Based Knowledge within CBP

Conducted knowledge workshop with importersUnderstand FDA process requirements (FDA person embedded in CEE during pilot)Port outreach in Chicago, Charleston, Atlanta, New York, Los AngelesProduct identification (authentic versus counterfeit)


Achieving Pilot Goals:Facilitate Legitimate Trade via Risk Segmentation

Port Profiles for Top 5 Ports Identify impediments to facilitationFind alternatives to paper requirements for every transactionPurge outdated targetingFinalize approvals for ISA Benefits ListDevelop policy guidance to improve uniformity


Achieving Pilot Goals:Enhance Enforcement and Address Industry Risks

CEE, FDA, and ICE personnel attended product training held by three major pharma importers.Special operation in LA coordinated with Trade, ICE, FDA, and Postal Inspectors• 193 Parcels examined• 34 Seized• 150 FDA referrals

Developed Enforcement Guide for ports to ensure consistency in seizure and elimination of lab testingSpecial Operation template for other ports


Industry’s Part in the Pilot

Industry workshop, 50+ attendeesQuarterly industry group meetingsMail blitz operationForum to discuss ISA wish listOpportunity to discuss concerns and current hurdlesFeedback surveysCommented on draft strategic plan


Now that it’s operational...

CEE Directors report to Directors, Field Operations in New York and Los Angeles, respectively• Leon Hayward, Pharmaceuticals• Anne Maricich, Electronics

Core staff includes: Attorney-Advisors, Entry Specialists, Field Analysis Specialists, Import Specialists, International Trade Specialists, National Account Managers, National Import Specialists, and Supply Chain SpecialistsThe Center combines both security and trade compliance personnel under one roof


Achieving Ongoing Goals:Increase Industry-Based Knowledge within CBP

Interact with relevant other government agencies to understand their processes and the impact on tradeRegular communication with internal and external stakeholdersServe as primary point of contact for trade and CBP personnel for industry-related issuesDevelop national policy to address industry-specific issuesIndustry-led training• Training sessions with Trade on business process • Trade training on identifying counterfeits (Enforcement)

Engage with small and medium-sized importers


Achieving Ongoing Goals:Facilitate Legitimate Trade via Risk Segmentation

Analyze imports by industry and segment riskCollaborate with other government agencies to develop alternatives to paper-bound requirements and/or blanket statementsIntegrate trade targeting efforts by industry to reduce exams and expedite cargo releaseMonitor cargo release for trusted traders and work with the Ports to resolve holdsRemove cargo release impediments (e.g., eliminate/raise trigger for automatic “docs required”)Manage and perform ISA oversight for trusted trader accountsMonitor and resolve uniformity issues and systemic barriersDevelop consistent policy guidance where needed


Achieving Ongoing Goals:Facilitate Legitimate Trade via Risk Segmentation (cont’)

Process post-entry work in CEE for trusted partners• Entry Summary• Protests• PEAs/PSCs• Reconciliation (coming soon)• Prior Disclosure Review (but PDs still filed with Port Director)• Process trusted partners as “Accounts”

General resource for brokers and importersBring willing entities into compliance/ISA (trusted trader status)


Achieving Ongoing Goals:Enhance Enforcement and Address Industry Risks

Counterfeit Enforcement:• National focus on IPR Violations• Collect information regarding seizures nationwide• Identify patterns and trends of illicit enterprises • Support Investigative units with intelligence and expertise (disrupt

distribution networks)• Coordination with the trade community

– Information sharing (website info, suspicious shipments, past info, internal investigations)

– Training manuals– Assistance with

TruScan library


Achieving Ongoing Goals:Enhance Enforcement and Address Industry Risks (cont’)

Addressing Industry Risks:• Focus the bulk of Officer and Import Specialist resources on known

and unknown high-risk shipments, while devoting fewer employees to manage trusted, low-risk importers

• Identify and target critical points in the import life cycle where product safety risks are greatest to protect consumers from health and safety concerns

• Develop pinpoint targeting and special enforcement operations in conjunction with OGAs


Benefits we’re seeing as an ISA company

Single point of contact for all issuesIndustry-based NAMs who are part of the CEECentralized entry summary – eliminates port inconsistencyFewer CF-28s/29s – pre-empted with phone call or email from NAM whenever possibleCentralized PEA filing – one place, one copy, electronicCentralized Protest filing – handled as a trusted trader accountAny issues with the above results in a dialog, not an automatic refusal/denial.Industry-based C-TPAT SCSS


Contact Info

Susie HoegerDirector, Global Trade Compliance & [email protected]

Check out the CEE article in the April 2012 issue of CBP’s Frontline magazine!

Simplified Entry

Matthew Varner, Nike(CBP slides reused with CBP permission)

May, 2012

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Simplifying the Entry Process

The Simplified Process joint industry-CBP Workgroup was established April 2011 with the goal of formulating viable

solutions that are mutually beneficial and diminish the administrative burden related to importing into the U.S. An outgrowth of that work was Simplified Entry, which reduces the number of duplicative data elements required to obtain release of products for cargo, eliminating the current entry

(CBP Form 3461).

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This simplifies the merchandise release process, allows for more streamlined electronic transmission for the filer, and assists importers in finalizing cargo

movement logistics.29

Simplified Entry Overview1. Filers will Submit a Streamlined

Data Submission

Filers will submit a reduced amount of information—12 required and three optional

data elements—prior to the arrival of the merchandise for transporting the cargo to the

U.S.

2. Filers can Provide the Information in Advance

The simplified entry can be filed earlier in the import process, allowing an expanded window of

opportunity to identify potential risks earlier.

3. Filers can Update the Data for Accuracy

It will also allow pilot participants to update entry information, providing CBP more accurate data and

enhancing cargo security.

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Enhances Cargo SecurityAllows CBP and the Trade to identify and address potential risks earlier in the process

Reduces Transaction CostsReduces transaction costs for importers and CBP by requesting filing data once

Greater predictability; allows importers to make logistical arrangements in advance of arrival

Reduces “exceptions” needing special processing after arrival

Expedites Cargo ReleaseExpedites data submission and cargo release decisions

Simplified Entry Benefits

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Simplified Entry Pilot Goals

The goals of the Simplified Entry Pilot are to reduce transaction costs, expedite cargo release and enhance cargo security.

Pilot Announcement

CBP received a total of 40 applications in response to its November 9 Federal Register notice announcing the pilot. In December 2011, U.S. Customs and Border Protection (CBP) selected nine brokers to participate in its pilot test of Simplified Entry for air cargo. Pilot participants will file entries for their clients.

Schedule

CBP has developed a pilot schedule that began with systems development, including ongoing testing, that allows for robust systems testing for both CBP and the Trade. The pilot was dependent on the completion of the ACE M1 deployment.

Now that ACE M1 has been deployed, CBP is targeting the week of May 28 to have the functionality in place to test the first filings of Simplified Entry.

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Pilot Participant Requirements*

*As additional functionality is phased into the pilot, these requirements will change

Air Mode of Transportation (MOT)

Brokers must be C-TPAT certified

Basic consumption entries only (Entry Type = 01 or 11)

Only shipments covered by a continuous bond

No split shipments

No other government agency requirements

Port of Unlading, Port of Entry, and Port of Arrival must be the same

Manifest quantities must equal the release quantities

Simplified Entry & Summary transactions must be filed in ACE

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Pilot Participants

1. A.N. Deringer, Inc.2. Expeditors3. FedEx Trade Network4. FH Kaysing5. Janel Group of New York6. Kuehne + Nagel Inc.7. Livingston International8. Page & Jones, Inc.9. UPS

Simplified Entry PilotPilot Ports

1. Chicago

2. Atlanta

3. Indianapolis Express Consignment Operation

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Simplify Entry streamlines the data elements on CBP’s 3461 entry form

This promotes the concept of “the owner of the data knows the data best”, resulting in more accurate information.

After the streamlining, the following Simplified Entry data set replaces the CBP 3461:

Simplified Entry Data

Simplified Entry Process

Remaining Flight TimePre-Departure WheelsUp

Arrival

Filer Carrier

Arrival Minus 4 Hrs Arrival

If the filer is using an ACAS carrier, CBP will indicate any bill match

The goods are officially released once they arrive

CBP will update the release message, as appropriate, as new information is updated

CBP will send a Status Message of the Entry once the ACAS and SE are

matched and targeting has been completed

Once the manifest is filed, CBP will match up the

manifest with the corresponding bill

Non-ACAS participants must wait until the manifest is filed before they receive any status

messaging from CBP

Resolve Any Holds Prior to Arrival

Simplified Entry

SubmissionTargeting Systems

ACAS* Submission

Flight Departure Targeting

SystemsUpdates

Manifest Submission

(AMS)Targeting Systems

ACAS system will indicate the Load Message once

targeting is complete

CBP receives the SE, and messages back a

data acceptance message, CBP will let the

filer know if there is a corresponding bill on file

The information can be updated by the Trade prior to arrival

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Next Steps

CBP is finalizing the deployment plan for the initial filings of Simplified Entry to include

Bringing on all pilot participants Expansion to other ports Inclusion of additional functionality such as the PG Message Set and DIS capabilitiesExpansion to other modes of transportation

CBP and the Pilot Participants will conduct an evaluation after 60 to 90 days to assess the pilot.

Outreach to the Trade Community will continue throughout the pilot. Information about the Simplified Entry Pilot, and other Trade Transformation Initiatives, is available on CBP.gov at:

http://www.cbp.gov/xp/cgov/trade/trade_transformation/

Beyond the Border and Trade Facilitation€¦ · Frontline. magazine! Simplified Entry Matthew...

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