CEE Participation Results in Fewer CF-28s and CF-29s From CBP, Report Says
Importers working with CBP’s Centers of Excellence and Expertise see fewer requests for information and notices of action than their counterparts that file at ports of entry, according to a report commissioned by CBP as part of its CEE rulemaking process (here). On average, participants see 78 percent fewer CBP Form 28s and 28 percent fewer CBP Form 29s after joining a CEE, which could be a sign that staff at the CEEs is becoming more knowledgeable and has less need to request more information, said the report, which was issued in 2015 but only recently released to the public.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
The decrease in requests for information results in less administrative time responding to the formal requests, which require staff time, and possibly legal review, said the report, prepared by Industrial Economics, a private consultancy. However, informal communication between the CEEs and trade participants has increased, with some issues formerly resolved through CBP Form 28s now handled by email, it said. “The increase in such communication would offset part of the administrative cost savings.”
CBP issued its interim final rule implementing the CEEs and making them permanent on Dec. 20 (see 1612190014). The end of the CEEs pilot shouldn’t add much cost for importers or CBP, the report said. With ACE fully functional, import data submitted by importers and their brokers will be automatically routed to the CEEs. CBP will see some costs associated with planning, outreach and training cease once the program is fully operational, the report said. The agency would incur personnel and operations costs regardless of whether entries are handled by ports of entry or the CEEs, the report said.
Some industry participants in the CEEs interviewed for the report said they were concerned the end of the test might mean less access to informally resolve questions on entry summaries, the report said. That might negate the reduction in requests for information and notices of action noted in the report, it said.
Based on fiscal year 2014 data, the report estimates that, once fully implemented, the electronics CEE will see the most entries, with more than 8 million entries over about 20 million entry lines valued at $388 billion. Though it will see fewer entries, the consumer products and mass merchandising CEE will process the most entry lines with 27,604,167 representing $217 billion in value. The petroleum CEE will process by far the fewest entries and entry lines – 640,323 and 851,979, respectively – but those entries and entry lines will represent the second-highest import value of any of the CEEs, at $351 billion.