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CBP's FAQ on Mandatory Advance Electronic Information Requirements for Inbound Air Cargo

On April 1, 2004, U.S. Customs and Border Protection (CBP) issued a first set of Frequently Asked Questions (FAQ) and responses regarding the mandatory advance electronic information requirements for inbound air cargo.

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(Although the actual title of this FAQ is "Air Automated Manifest System Frequently Asked Questions," it is listed on CBP's Web site as "Air FAQs on the Trade Act of 2002 - Mandatory Advanced Electronic Cargo Information.")

This is Part IV of a multi-part series of summaries on this FAQ, and highlights FAQs 9-12. See future issues of ITT for additional summaries.

FAQ 9 - Split Consolidated Shipments

House air waybill information. In response to a question asking, when a carrier splits a consolidated shipment, is the carrier required to send any information for the associated house air waybills, CBP states that for consolidated shipments covered by a master air waybill, the carrier is required to report to CBP certain information regarding each associated house air waybill to indicate which house air waybills have been laden on each flight.

Single entry may be filed. CBP states that it has an existing policy to allow a single entry to be filed for a split shipment provided that the conditions of 19 CFR Part 141.57 have been satisfied. If these conditions are satisfied, the entry filer must include additional information on the CBP Form 3461. (See FAQ for these additional information requirements.)

In order to transmit an electronic permit to release for each portion of a split shipment, CBP states that it must post such release to each portion covered by the single entry or special permit for immediate delivery. To effect such release, the importer must provide a copy of the CBP Form 3461 to CBP with the information listed in the FAQ. If the release is to occur incrementally, the filer must provide such notification to CBP upon arrival of each portion of the shipment.

FAQ 10 - Information for Consolidated Shipments

Multiple shippers/consignees. CBP states that it requires detailed shipper information on each air waybill record for the purposes of targeting high-risk shipments. If a freight forwarder or other consolidator receives merchandise from multiple foreign vendors and arranges for such transport to the U.S., listing the freight forwarder as the shipper would not provide sufficient information for CBP to conduct its targeting. According to CBP, Air AMS does not have the capability of accepting multiple shippers or consignees for a single air waybill record, nor could it be readily adapted to so accept multiple shippers/consignees.

Consolidation identifier. CBP explains that the consolidation identifier is a conditional element in the air waybill line of an Air AMS message. An Air AMS participant includes the value "M" to identify an air waybill as a master air waybill which indicates that one or more house air waybills is associated with that master air waybill.

Master air waybill with only one house air waybill. CBP responds to a question on whether, if a master air waybill record has only one associated house air waybill, can the carrier report this as a simple air waybill, by stating that when a master air waybill references only one house air waybill, both the master air waybill and the house air waybill must be reported.

FAQ 11 - Master and House Air Waybill Information

In response to a question asking if Air AMS requires the carrier to transmit the master air waybill record before another party may transmit house air waybill records associated to that master air waybill, CBP states that it has undertaken efforts to modify certain critical aspects of Air AMS by May 13, 2004. According to CBP, one of these new processing edits will allow the receipt of house air waybill information prior to the receipt of the master air waybill record from the importing carrier.

FAQ 12 - House Air Waybill Format

12 alphanumeric characters. CBP indicates that the data field for house air waybill numbers will accept 1-12 digits of alphanumeric characters.

CBP further states that an Air AMS participant is required to report the full house air waybill identifier as printed on the hard copy document. This includes alpha characters preceding or contained within the house-level shipment identification.

Sub-house air waybills. According to CBP, a sub-house air waybill refers to multiple house air waybills that are consolidated into a single (consolidated) house air waybill record. The sub-house air waybill would contain the identity of the shipper and consignee, while the consolidated house air waybill record may only list the consolidator/forwarding agent as the shipper and consignee.

Since Air AMS can only accommodate one level of house air waybill identification, CBP states that an Air AMS participant must report the sub-house air waybill information in the house air waybill field. The consolidated house air waybill information need not be reported.

(See ITT's Online Archives or 04/08/04, 04/16/04, and 04/19/04 news, 04040805, 04041605, and 04041915, for Parts I-III of this series of summaries on this FAQ.)

CBP's air cargo FAQ (dated 04/01/04) available at http://www.cbp.gov/ImageCache/cgov/content/import/communications_5fto_5ftrade/mandatory_5fadvanced_5felectronics/air_5ffaq_5fcargo_2edoc/v1/air_5ffaq_5fcargo.doc