Submissions for APHIS' May 31 Lacey Act ALR/BRASS Pilot Deadlines Must be Postmarked by May 30
Animal and Plant Health Inspection Service sources have stated by phone that letters of intent to participate in the Lacey Act Blanket Declaration Pilot Program must be postmarked by Saturday, May 30, 2009 (as the May 31, 2009 deadline falls on a Sunday).
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Similarly, the first estimated PPQ 505s (for June 2009) must be postmarked by May 30, 2009.
APHIS sources previously stated by phone that the date by which eligible entities must contact APHIS to participate in the Lacey Act Blanket Declaration Pilot Program was effectively extended until May 31, 2009. In addition, the date by which a pilot participant must file their first estimated PPQ 505 (for June 2009) was effectively extended until May 31, 2009. (See ITT's Online Archives or 05/19/09 news, 09051905, for BP summary of APHIS sources announcing the extension for the pilot program.)
Note that the June reconciliation report is due by July 15, 2009.
(APHIS is implementing 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. 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 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 previously stated 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 had noted that they would 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.
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