COAC Calls for Dates to Be Provided When CBP Issues Regulatory Requirements
The Commercial Customs Operations Advisory Committee is urging CBP to provide dates when posting information on the implementation of tariff and other trade-related policies, according to a list of recommendations that the committee provided to CBP ahead of the Sept. 17 quarterly meeting.
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"COAC recommends that CBP provide electronic messages for dates upon which regulatory and statutory requirements depend to ensure accurate duty collection and to meet other regulatory requirements," says the first item in COAC's list of recommendations for CBP. "These pertinent dates are required for duty calculation and other cargo processes such as ISF, General Order, In-Bond, currency exchange rates, and Quota."
COAC continued, "CBP and Trade must have confidence in the dates upon which regulatory and statutory requirements depend. These dates must be made available in both manifest queries and via Cargo Release Status Messages."
COAC's list of seven recommendations, offered by the full committee, comes as the Sept. 17 quarterly meeting is slated to be the last meeting of COAC in its current iteration. CBP plans to restructure COAC to align the committee's work with CBP's focus on national security, the protection and promotion of domestic industry, and the closure of “revenue and enforcement gaps” caused by unfair trade practices, according to July 1 communications from the agency to the trade (see 2507010077).
The other six recommendations are:
- CBP should develop a chatbot to address frequently asked questions associated with the tariffs and tariff-related issues, including but not limited to tariff stacking, the removal of de minimis, the utilization of postal channels and other core definitions.
- CBP should implement the use of the Electronic Permit to Transfer (ePTT) system for all bonded movements within a port, across all modes of transportation.
- CBP should retire existing paper-based in-bond processes, including but not limited to CBP Form 6043, with electronic alternatives to enhance efficiency and accuracy.
- CBP should update its guidance document on setting bond amounts so that the rounding rules for the Activity Code 1 continuous bond eliminate the $10,000 increments when a bond amount would be more than the minimum $50,000 and less than $100,000 (the next higher increment for a bond, after the $50,000 minimum, should be $100,000).
- CBP should undertake a step to standardize the physical and mailing addresses when it's creating or updating a name and address through the use of CBP Form 5106 or its electronic filing equivalent.
- CBP should identify the physical addresses frequently used by P.O. Box centers, business service centers, etc. that may be of higher risk of erroneously being reported to be a physical location of a business or individual.