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APHIS Extends Two Deadlines for Lacey Act ALR/BRASS Pilot to May 31st

Animal and Plant Health Inspection Service sources have stated by phone that the date by which eligible entities must contact APHIS to participate in the Lacey Act Blanket Declaration Pilot Program is "effectively extended" until May 31, 2009.

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Similarly, the date by which a pilot participant must file their first estimated PPQ 505 is extended until May 31, 2009. (The previous deadline for both was May 15, 2009.)

APHIS sources added that the June reconciliation report is still due by July 15, 2009.

(APHIS has previously stated it will implement the pilot program using a two step process. In Step 1, the Automated Line Release (ALR) or Border Release Advance Screening and Selectivity (BRASS)1 participant will file with APHIS an advance estimated PPQ 505 on or before the 15th day of the month prior to the reporting period.

The deadline for the first estimated PPQ 505 is now May 31, 2009, covering expedited release shipments planned for the month of June 2009. For Step 2, the participant must file with APHIS a reconciliation report within 15 days after the end of the month, for the previous month, that provides information on the actual shipments made. The deadline for June's reconciliation is July 15, 2009.

The pilot is initially open to those entities currently participating in CBP's expedited border release program, ALR/BRASS, whose products require a Lacey Act declaration during the current phase of enforcement. (The current phase is limited to nine HTS headings in Chapter 44 (wood and articles of wood).)

C4 Codes Still Expected to be Deactivated for Non-Pilot Participants on June 1st

APHIS sources note that the June 1, 2009 expedited program removal date and C4 code deactivation date for those that do not wish to participate in the pilot program remains June 1, 2009. APHIS sources add that they will be providing a list to CBP of those that have opted to participate in the program so that CBP does not deactivate their code or remove them from ALR/BRASS.

1Though some still use the term Line Release, CBP has stated that the BRASS system replaced the former Line Release system. BRASS tracks and releases repetitive shipments at land border locations.

(See ITT's Online Archives or 05/13/09 news, 09051310, for BP summary of APIHS issuing filing instructions and the form for the pilot program.)

APHIS instructions for the pilot program's forms (posted 05/12/09), available at http://www.aphis.usda.gov/plant_health/lacey_act/downloads/Instructions.pdf

Blanket declaration reconciliation spreadsheet (with 30 headings, posted 05/12/09) available at http://www.aphis.usda.gov/plant_health/lacey_act/downloads/BlanketDeclarationReconciliation.xls

General instructions on pilot (posted 05/05/09) available at http://www.aphis.usda.gov/plant_health/lacey_act/downloads/PilotProgramAnnoucement.pdf