COAC Members and CBP Officials Tout Continued Partnership Amid Shakeup

The COAC, currently in its 17th term, was informed in July that CBP is restructuring the committee to align COAC's activities with CBP's new focus on national security, protecting and promoting domestic industry, and closing “revenue and enforcement gaps” caused by unfair trade practices (see 2507010077).

As a result of this restructuring, COAC's current activities would wind down, according to CBP, with September being the last meeting of COAC in its current iteration.

However, at the Sept. 17 meeting, Laurie Dempsey, deputy executive director for CBP's Office of Trade, concluded the meeting by saying that the next COAC meeting would occur in December. CBP's website also indicates a December meeting. No further details were provided.

Since September was the last meeting of COAC as it presently stands, the committee provided CBP with over 70 recommendations from subcommittees working on intelligent enforcement, next generation facilitation and secure trade lanes.

"Change is hard, but I know that we are up to it, and we will show our strength as leaders. I hope that we challenge the status quo and provide every opportunity to set a new course for COAC to advise and be that voice of trade," COAC Co-Chair Julie Pojar said during the meeting's opening remarks. "This is a challenging time for everyone right now in the trade community, and I hope that we can continue to lift up the challenges that we face to those that can act upon them. In addition to challenges, I hope that we find opportunities to advise on enhancements, efficiencies and ways to support the trade in the U.S. industry."

Pojar also told federal officials at the meeting that the trade is ready to share its insights, knowledge and experiences to make "trade stronger, more efficient and more compliant."

COAC co-chair Dave Corn noted that COAC has previously undergone restructuring, saying that even though "this is not the first time that we have seen a shift ... it certainly will not be the last. Maybe the structure as we know it is winding down, but only to come back with a different and new focus."

"We are constantly introduced to new wrinkles in life that are presented to us, and we can choose to look at those as problems, or we can work to find opportunities or solutions for those situations that come our way," Corn said. "You'll see these solutions are going to be important, obviously vital, for our industry to continue to recommend the best ways to facilitate the movement of cargo through our Great Nation, safely, effectively and efficiently, to facilitate for all involved as we continue this effort in light of this restructuring."

COAC member Lisa Schulte echoed Corn's sentiments, saying, "the importance of collaboration in the space remains vital. While our working groups are winding down, we look forward to a new phase of advisement, where COAC and CBP will engage on topics that are timely and critical to achieving our respective goals."

Meanwhile, federal officials at the meeting expressed their gratitude to the trade, saying the government depends on their expertise.

"I want to acknowledge the COAC's resilience. Your expertise is critical as we focus on high-priority trade efforts, particularly in making sure that CBP has the right tools to deter bad actors who pose threats to American consumers and American businesses," said Kevin Salinger, acting assistant secretary for tax policy at the Department of the Treasury.

"Now we know that change can be challenging. This administration is moving quickly, and there is much work still ahead to ensure that trade is fair and delivers benefits for all Americans," Salinger continued.

Remarks from CBP officials also appeared to indicate a continued partnership between the government and the trade, although the official parameters of that partnership remain to be seen for now.

"While CBP is responsible for enforcing the rule of law, including the president's tariffs, we're also committed to facilitating legitimate trade. As changes occur, CBP will continue to communicate with the trade community and provide detailed guidance to promote compliance and uniform enforcement across the nation," CBP Acting Deputy Commissioner John Modlin said during the meeting's opening remarks.

In discussing the recommendations from the Next Generation Facilitation Subcommittee, CBP's Shari McCann said: "CBP really appreciates the dedication of our COAC and working group members and the hard work that went into developing these productive recommendations from industry. These recommendations address some longstanding and significant needs for improvement," including bringing key post-release processes into regulations.

"We look forward to further reviewing and working on these recommendations, with the intent to lead our overall processes into greater efficiencies," McCann continued.

Dennis McKenzie, CBP deputy executive director for cargo and conveyance security, also said his agency would continue to work with the trade on outstanding issues.

"We're going to continue that work. We'll continue the partnership, no matter what form the COAC takes. You'll still see us out at the association meetings, working in the summit, working with the individual associations, with the individual companies, etc., not only the ones in the United States, but also Mexico and Canada, as part of you and are under USMCA," McKenzie said. "I'm not going to belabor it... but I just personally want to thank everybody for all the hard work, all the time invested."

The committee passed all the recommendations to CBP. While working group chairs generally summarized their recommendations, there were some additional remarks beyond the recommendations.

COAC member Cynthia Roller, who sits on the export modernization working group, said she hopes that the final rules for the electronic export manifest for rail would address public comments that identified operational and system impediments that rail carriers could face under the current notice of proposed rulemaking.

"There is a lot more work to be done in this arena, and NPRM to the final rule to operational reality can be miles apart. We are concerned about those miles as well as the things that we just don't know yet," Roller said. "There is a real benefit for CBP to engage with trade to ensure that CBP meets its mission to successfully deploy and receive meaningful data benefits. It is also needed for trade to be compliant without major disruption to the fluidity of the supply chain and cargo movement."

A public comment from TEU Global, a third-party logistics provider specializing in pharmaceutical and healthcare logistics, asked CBP to consider a working group or subcommittee focused exclusively on pharmaceuticals and life sciences trade in order to facilitate discussion between CBP, the FDA and pharmaceutical importers.

"With COAC’s undergoing restructuring and subcommittees are being phased out, it is a timely opportunity -- and a clear need -- for the creation of a Pharmaceutical/Life Science working group," Bonni van Blarcom said on behalf of TEU Global. "Many COAC recommendations exist on these issues. Work should continue on these topics, to refine recommendations to new developments and continue efforts for their implementation."