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NMFS ACE Filing Burden Estimates Well Short of Actual Time Required, NCBFAA Says

The promise of the International Trade Data System “has unfortunately not been matched by reality,” with duplicative and repetitive entry requirements for partner government agencies, including the National Marine Fisheries Service, the National Customs Brokers & Forwarders Association of America said in comments on NMFS implementation of ITDS submitted to the Office of Management and Budget.

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“The Single Window has instead become a multi-paned window,” the NCBFAA said in the comments, dated March 6.

The NMFS estimate that it takes 18 minutes to submit its dataset in ACE “is not a realistic estimate,” the NCBFAA told the OMB. “It is true that one simple commodity from one harvest point on a single day can be input into the system in the estimated 18 minutes,” the trade group said. “The problem is that seafood supply chains are long and complex, flowing in multiple directions. The seafood in a shipment comes from different vessels harvested at different locations.”

For example, a shipment of 20 containers holding 60,000 tins of canned seafood might include products from “10 or 12 different vessels catching fish from over a hundred different locations,” causing the 15 additional NMFS data elements to “explode into thousands of data elements at entry,” the NCBFAA said.

For some species, the same data must be “entered again and again for multiple NMFS programs,” the NCBFAA said. Some tuna can come in under three different NMFS programs and require entry data for each vessel, catch date and location, adding up to hours of data entry. “The required three different data sets cannot be combined on one entry, but must be entered separately,” the trade group said.

Similarly, because of the way the Harmonized Tariff Schedule is structured, data for shrimp must be entered by size, the NCBFAA said. “This can require multiple duplicate data sets per entry,” it said. Even shipment of shrimp that’s all the same size from four ponds, harvested on four different dates, requires 16 data sets for one entry. “Based on 18 minutes per data set, it would take over 4 hours to do the entry, not even considering there may be different sizes. In the real world, the input is a lot more than the 18 minutes suggested,” the NCBFAA said.

And the process involves “more than just the physical input of data,” the NCBFAA said. “The NMFS estimates fail to account for the substantial amount of pre-entry work in gathering, sorting and compiling the data prior to keying it into the ACE system.”