Trade Groups Lay Out Current Filing Status of PGAs for FTZs in Letter to CBP
Several partner government agencies (PGAs) have now confirmed in writing that they will attach their message sets to e214 electronic Foreign-Trade Zone admissions filings once they are available in ACE, trade associations said in a Feb. 21 letter to CBP. The Animal and Plant Health Inspection Service (for both its core and Lacey Act data sets), the Fish and Wildlife Service and the National Highway Traffic Safety Administration have all said they will switch from current PGA message set filing at the time of type 06 entry/entry summary filing to at time of admission to the zone once the e214 is deployed, the letter said.
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NHTSA, which currently requires filing at time of cargo release for regular entry filers or with the weekly entry summary for weekly filers, had been asked by the National Association of Foreign-Trade Zones not to switch its point of transmission to FTZ admission. NAFTZ had questioned whether the move to earlier filing would be productive, given how much work it has taken to figure out filing an entry summary of NHTSA, a software developer said last year (see 1702150037). NHTSA rejected the NAFTZ request in a response sent in November, the letter said.
The American Apparel and Footwear Association, the National Retail Federation and the U.S. Fashion Industry Association signed on to the letter alongside NAFTZ. The letter was meant to “inform [CBP] and the Border Interagency Executive Council (BIEC) of current status and remaining PGA issues in ACE for FTZ stakeholders,” it said.
Generally, agencies should avoid double reporting, the letter said. If a PGA collects import data at the time of admission, then reporting on the type 06 entry should not be required, it said. Likewise, if the PGA collects data at the time of the type 06 entry, then reporting at time of admission should not be required. “There are also additional outstanding issues on how the PGAs through ACE will handle adjustments, zone-to-zone transfers, and the unique aspects of manufacturing zones,” the letter said.
The Drug Enforcement Administration has verbally confirmed that its import declarations will be required at time of admission once the capability is available in ACE. NAFTZ has also asked the Environmental Protection Agency to allow filing of notices of arrival at time of admission for merchandise regulated under the Federal Insecticide, Fungicide and Rodenticide Act. Other agencies, including the Bureau of Alcohol, Tobacco, Firearms and Explosives, the Alcohol and Tobacco Tax and Trade Bureau, the Food and Drug Administration and several other EPA programs, are set to require PGA message set filing at time of entry or entry summary, the letter said.