ACE and PGAs. The Challenge to the Broker. The Challenge to the Broker Amy Magnus A.N. Deringer, Inc.

Transcription

1 ACE and PGAs The Challenge to the Broker

2 ACE Roll Out 2016 the year of the roll outs ACE Release Processing PGA Pilots PGA Mandatory Use Almost Reconciliation, Drawback, ACE Statement 2016 A.N. Deringer, Inc.

3 ITDS From ensuring motor carrier safety to safeguarding against hoof and mouth disease, the 47 ITDS Partner Government Agencies (PGAs) currently slated for ACE integration, are as diverse as international trade is complex. PGAs represent ten cabinet level and four independent departments/agencies. Many PGAs are commonly known, others are less publicly visible. All are equally vital to keeping the commerce crossing our borders safe, secure and legitimate.

4 Brokers Preparation CBP and PGAs release CATAIR and Implementation Guides Brokers Software providers program ABI according to new specifications found in CATAIR and IGs Brokers test new upgrades, install, train, reach out to clients for additional data, pilot, and implement as the specifications are rolled out.

5 Myra s IGs

6 Implementation Guides or Myra s Race to the Ream 47 Participating Government Agencies 15 Implementation Guides issued as of Aug. 31, Pages of instructions 6 Appendices 423 Pages of instructions 13 Agencies list more than one update 41 updates total APHIS 8/29 IG is the winner in the Race to Ream (412 pages) - followed closely by FDA 356 pages

7 2016 Mandatory PGAs DOT - NHTSA - National Highway Traffic Safety Administration FDA Food And Drug Administration APHIS Lacey Act NMFS National Marine Fisheries Service Tuna/ Tuna Products NMFS - AMR - National Marine Fisheries Service - Antarctic Marine Living Resources NMFS - HMS - National Marine Fisheries Service - Highly Migratory Species

8 PGAs Yet to Come APHIS Core - Animal and Plant Health Inspection Service ATF - Bureau of Alcohol, Tobacco, Firearms and Explosives CPSC - U.S. Consumer Product Safety Commission DDTC - Directorate of Defense Trade Controls DEA - Drug Enforcement Administration EPA - ODS - Ozone Depleting Substances EPA - PST - Pesticides (FIFRA) EPA - TSCA - Toxic Substance Control Act EPA - VNE - Vehicles and Engines FWS - U.S. Fish and Wildlife Service OMC - Office of Marine Conservation TTB - U.S. Department of the Treasury, Alcohol and Tobacco Tax and Trade Bureau USDA - AMS - Agricultural Marketing Service USDA - FSIS - Food Safety and Inspection Service

9 USDA APHIS Core Complexity Veterinary Services (AVS) Live animals, related animal products and byproducts Plant Protection and Quarantine (APQ) Propagative material, seeds not for planting, fruits and vegetables, cut flowers Biotechnology Regulatory Services (ABS) Genetically engineered organisms Animal Care (AAC) Live animals, dogs

10 APHIS DATA There were a total of 1392 data elements within the various forms among APHIS programs that were converted to data.

11 Fish and Wildlife Complexity National Retail Federation drafted a letter to CBP on 9/7/16 detailing the following: One member reported that prior to the pilot they had 40 HTS lines flagged, but under the pilot, they had 146 lines flagged. They went from 4,000 products to 14,000 products requiring F&W reporting.

12 F&W HTS 4 Categories FW2 Requires extended data set (EDS) Contains animal products, but HTS isn t detailed enough to make a determination (must submit a limited data set N or Y, or an EDS) HTS is highly likely to require EDS (either a certified declaration that no EDS is required, or a full EDS is required) No HTS Flag it s the responsibility of the importer to know whether or not F&W applies

13 Fish and Wildlife Complexity May require data or a disclaim by certifying individual N1 Applies to certain wholly domesticated or extinct mammals. N2 Applies to certain mammals, birds and insects when they are of a domesticated source. N3 Applies to domesticated mice and rats for biomedical or scientific purposes. N4 Applies to U.S. Salmonids from a non-protected population when no salmonid certification is required. N5 Applies to Salmonids with a species country of origin other than the U.S. when no salmonid certification is required. N6 Applies to U.S. Salmonids from a non-protected population when a salmonid certification is required. N7 Applies to Salmonids with a species country of origin other than the U.S. when a salmonid certification is required. N8 Generic scenario applies to other species as appropriate. N9 Applies to all other salmonids when a salmonid certification is required. N10 Applies to mitten crab other than live specimens. N11 Applies to vegetable/human/wildlife combined products. N12 Applies to vegetable/human/wildlife combined products.

14 Fish and Wildlife Complexity F&W Applies Require Data Y1 Applies to certain mammals, birds, insects that are not domesticated. Y2 Applies to domesticated mice and rats for other than biomedical or scientific purposes. Y3 Generic scenario applies to other species as appropriate. Y4 Applies to foreign origin salmonids that are protected. Y5 Applies to U.S. origin salmonids from a state where protected. Y6 Applies to protected fish species. Y7 Applies to protected mollusks. Y8 Applies to live mitten crab. Y9 Applies to vegetable/human/wildlife combined products. Y10 Applies to scenario N6 when trade cannot certify. Y11 Applies to scenario N7 when trade cannot certify.

15 Environmental Protection Agency Complexity Vehicles and Engines off road Vehicles and Engines on road Pesticides Notice of Arrival Ozone Depleting Substances TSCA Certification

16 Multiple PGAs in One File? One Entry of spare parts for autos- 911 Entry Summary Lines NHTSA EPA - EPA - EPA - FDA - FDA - FWS - Parts subject to FMVSS, FMVTPS Vehicles and Engines Pesticides Pumps for autos TSCA Paint Pens and Fluids Radiation Emitting Devices CD Players Medical Devices Car Cover Leather Seats

17 PRE ITDS Submission of NHTSA data

18 What is required to be submitted now For one windshield, from one supplier, from one country

19 80 PGA lines 2016 A.N. Deringer, Inc.

20 Contact Information Amy Magnus, LCB, CCS, & b12