CPSC Risk Assesment Model (RAM), CBP Automated Commercial Environment (ACE), & Pilot Programs

U.S. Consumer Product Safety Commission

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This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.

CPSC Staff Workshop on Electronic Filing of Certificates as Included in Proposed Rule on

Certificates of ComplianceSeptember 18, 2014

For those of you in the room, please mute electronics and phones.

For those of you watching on the web, you can email questions for the speakers to: [email protected].

The transcript for today’s workshop will be added to the docket at: www.regulations.gov Docket number: CPSC–2013–0017

The PowerPoint presentations will also be available at: http://www.slideshare.net/USCPSC

CPSC Staff Workshop on Electronic Filing of Certificates as Included in Proposed Rule on Certificates of

Compliance

mailto:[email protected]

http://www.regulations.gov/

http://www.slideshare.net/USCPSC

CPSC Risk Assessment at Import

John Blachère

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This presentation has not been reviewed or approved by the Commission and may not reflect its views

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Presentation AcronymsHTSUS – Harmonized Tariff Schedule specific to the

United StatesITDS – International Trade Data SystemCBP – U.S. Customs and Border Protection

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Certificates – Current CPSA section 17(a)(2) - requires the

Commission to refuse admission for regulated products not accompanied by a certificate

CPSA section 14(a)(2) – requires testing and certification before importation

CPSA section 14(g)(3) – requires certificates to accompany the product or shipment of products, as well as be provided to CPSC and CBP upon request.

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Existing 1110 RulePaper or electronic certificates (URL typically on the

product, container, or invoice)Electronic certificates must be created before importationAvailable to CPSC and CBP as soon as the product or

shipment itself is available for inspection.

In practice, Certificates:Obtained and reviewed at the time of entry through

broker or importer which may take time to present and may delay release

No ability to assess industry compliance with requirement

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Certificates - ProposedProposed rule (proposed 16 CFR §1110.13) –

certificates for imported products must be filed electronically with CBP at the time of filing the CBP entry or at the time of filing the entry and entry summary, if both are filed together.

Aligns with Executive Order 13659: “Streamlining the Export/Import Process for America's Businesses”

Entering required data elements for certificates at the time of entry would allow the agency toElectronically review and facilitate releasePrioritize examinations with certificate data at entry

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Risk Assessment Methodology (RAM)CPSA Section 17(h)(1) Requires CPSC to:

Establish and maintain a permanent product surveillance program, in cooperation with other federal agencies, to carry out the Commission’s responsibilities and to prevent the entry of unsafe consumer products into the commerce of the United States.

CPSIA Section 222(a) Requires CPSC to:Develop a Risk Assessment Methodology (RAM) that identifies

shipments of consumer products that are (1) intended for import into the United States; and (2) likely to include consumer products in violation of

Section 17(a) of the CPSA (15 USC 2066(a)) or other

import provisions enforced by the Commission.

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Risk Assessment Methodology (RAM)CPSIA Section 222(b) requires CPSC RAM

development to:Use CBP’s ITDS insofar as practicable, Incorporate the RAM into CPSC’s IT

modernization plan, and Examine how to share information with CBP for

the purpose of identifying risky shipments.

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Total Risk Management at ImportMonitoring

Shipment activity by product, entity, and port/regionViolation history/risk by product, entity, and port/region

Address risk in product areas and entities at import.Examples:

Limited complexity: ATVsHigh complexity: Toys

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Risk Assessment Program ComponentsIntergovernmental Memoranda of Understanding

and agreementsCollocated personnel with CBPIntegration with CBP data systems - pilot systemOther improvement projects

Product codingInternal case and process monitoring

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Collocated StaffWorks cooperatively at ports to target and screen shipments Chemical analysis – XRF and FT-IRMechanical analysis – Use/abuse and physical

assessmentDocument verification – Certification and tracking

labels

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Pilot System (ITDS/RAM)Integrates available risk information to model and support Commission enforcement strategy involving product hazards at importation

Potential sources of risk data include: Shipment (CBP) Case history (CPSC & CBP) Examination history (CPSC) Injury and death (CPSC) Commercial information (Third Party)

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Pilot System FunctionsStatistical modeling to assist in the prioritization

of projects and operationsRisk-based standard reporting for product

managers to know importation patternsGraphical User Interface to manage screening

and exams at ports of entrySystematic assessment methodology to review

and prioritize all shipments of potential

interest to CPSC15

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CPSC-CBP Data Synchronization

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HTSUS ReclassificationWork with the U.S. International Trade Commission on the reclassification of some product areas to support regulation enforcement and defect identificationCompleted once for the January 1, 2011 mapping

ToysATVsChildren’s Durable ProductsDrywall

Second set under review

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Modernizing Certificate CollectionWill:Reduce the shipments reviewed that are compliant

or out of scopeReduce the time spent per shipment to verify

compliance with our lawsImprove the rate of discovery of hazardous/violative

products per staff monthProvide a single, reliable store of certificate data

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CPSC Risk Assessment at Import

John Blachère

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This presentation has not been reviewed or approved by the Commission and may not reflect its views

Single Window and Automated Commercial Environment

(ACE)

Brenda SmithACE Business Office

CPSC Workshop on Electronic Filing of Certificates at Entry

September 18, 2014

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Single Window Authorization and Support

Executive Order signed February 19, 2014 – Streamlining the Export / Import Process for America’s Businesses

Directs 47 U.S. Federal agencies with a role in trade to be ready to participate in the electronic “Single Window” by December 2016

Expands scope of the Border Interagency Executive Council (BIEC) to all agencies with a border interest

ITDS Board of Directors provides executive leadership and direction, and works with PGAs on automation

ACE Executive Steering Committee (DHS and CBP executives) provides oversight and guidance to the ACE Program to ensure successful development and operation

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IT Foundation for the Single WindowACE will automate trade processing and data collection for 47 federal agencies

Increased USDA food seizures 30-foldAutomated processes saving CBP $46M/year

Enhances agency enforcement missions through trade targeting and risk segmentation

Reduces U.S. supply chain transaction costs

Streamlines interagency processing through collaboration and less paperwork

Strengthens the global supply chain to protect U.S. interests and enhance prosperity

Supports U.S. manufacturing growth by facilitating exports

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Automated Commercial Environment

33% faster truck processing Up to 76% duties/fees paid interest free via ACE

Nine agencies receiving automated data via ACE

Pre-arrival data linked and available in ACE

Participating ocean carriers saving $900K/year in reduced courier costs

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Three enablers provide the means for Partner Government Agencies (PGAs) to participate in ITDS/ACE

Partner Government Agency (PGA) Message Set - Establishes a single, harmonized set of information to be collected electronically from international traders by CBP on behalf of PGAs

Interoperability Web Services - Provides a system-to-system pipeline for data transfer between CBP and PGAs

Document Image System (DIS) - Allows trade members to supply images of needed documents electronically during the cargo import and export processes

Implementing the Single Window

The ACE portal provides PGAs with a graphical user interface (GUI) to view the data in ACE, search on that data and run reports. The ACE portal

is a consistent interface across PGAs that differs only by their particular information and processing needs.

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PGA Integration Status

PGA Message Set Document Image System (DIS)

Interoperability Web Service (IWS)

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Developed In Progress Remaining

PG

As

• CPSC is among the nine agencies using IWS capabilities

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PGA Message Set Processing Benefits Today, PGA data is submitted manually via paper forms, requiring human

intervention and manual correlation with transactions

PGA Message Set extends existing CATAIR message set to allow submission of PGA data electronically to CBP along with entry and entry summary filings

The Single Window will streamline transmission, processing and distribution of PGA data, yielding significant cost savings and efficiency:

Trade and multiple government agencies will no longer exchange information via multitude channels during the cargo release process

Data will be available to agencies more quickly, allowing for better identification of dangerous or prohibited shipments

Automated PGA interactions reduce paper and enable near-real time decision making by Government authorities

Single Window makes it easier for industry to comply with government regulations and reduces costs for Government and industry

PGA Onboarding Process 47 PGAs to be on-boarded in three phases, beginning with PGAs with Cargo Release responsibilities

Phase I – Initial capabilities deployed to 10 agencies by April 30, 2014 Phase II – Advanced capabilities deployed to 13 agencies by July 4, 2015 Phase III – Advanced capabilities deployed to remaining agencies by

July 1, 2016

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IWS enabled October 2011 CPSC receiving production entry and entry summary data

directly from CBP CPSC upgraded to advanced Event Exchange capability in IWS

on September 10, 2014 CBP and CPSC are engaged in on-going discussions to plan

for exchange of forms via DIS to supplement the admissibility review process Planning to be DIS capable with July 4, 2015 ACE deployment

CPSC Connectivity Status

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Date Mandatory Requirement Time Remaining

May 1, 2015 Mandatory use of ACE for electronic import and export manifest filings

8 months

November 1, 2015 Mandatory use of ACE for electronic Cargo Release and related Entry Summary filings

14 months

October 1, 2016 Mandatory use of ACE for all remaining portions of the CBP cargo process

25 months

Mandatory Dates for Transition to ACE

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Questions?

Visit http://cbp.gov/ace

Or e-mail us at: [email protected]

http://cbp.gov/ace


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PGA Data Processing: Architecture

Food Safety and Inspection Service

Food Safety and Inspection Service Pilot for PGA Message Set

Bob BerczikInternational Relations and Strategic Planning StaffOffice of Public Policy and Program Development

Food Safety and Inspection Service, USDA

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Food Safety and Inspection Service:Mission in Action

We are the public health agency in the USDA responsible for ensuring that meat,

poultry, and processed egg products are safe,

wholesome, and accurately labeled.

• Federal Meat Inspection Act (FMIA), 1906• Agricultural Marketing Act (AMA), 1946• Poultry Products Inspection Act (PPIA), 1957• Humane Methods of Slaughter Act (HMSA), 1958• Egg Products Inspection Act (EPIA), 1970

Our AuthorityThrough a series of Acts, Congress empowers FSIS to inspect all meat,

poultry, and processed egg products in interstate commerce.

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Public Health Information System (PHIS)

o Designed to collect, consolidate, and analyze data derived from both domestic inspection and foreign country inspection systems

o Centralized computer database that generates random import inspection tasks and stores inspection results, based on:

• Exporting country, process category, species, performance

o Interconnected with US Customs and Border Protection’s (CBP) Automated Commercial Environment (ACE)

o Pre-populates shipment data received from industry, enhancing controls and reducing fraud

• PHIS connection to ACE• Partner Government Agency (PGA) Message Set

PGA Message Set Pilot underway with two brokers making entries at three POEs with nationwide implementation to follow

o GOAL: to streamline the Customs entry process and transition away from paper –based application process for FSIS import inspection

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PHIS

o Enables interface with U.S. Customs and Border Protection’s Automated Commercial Environment (ACE) system

• Business-to-government exchange of shipment data

• Provides FSIS Advance Notice when Customs entry filed

• Replaces paper application for inspection (Form 9540-1)

Uses existing data collected by CBP Incorporates FSIS specific data into the CBP standard data set

(UN/CEFACT and WCO compliant)

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o Importers are required to apply for FSIS import inspection for all entries of meat, poultry, and egg products

o An Entry or Entry Summary Certified for cargo release in ACE, combined with the PGA Message Set, will eliminate the need for paper applications

• An electronic FSIS Form 9540-1 will expedite the clearance process on regulated shipments

FSIS Import Application (FSIS Form 9540-1)

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o Electronic import application in PHIS retrieves data from ACE• PGA Message Set data completes

the data fields missing from the FSIS import application

o For example• Broker information provides local

broker first name*, last name*, phone number,* email address* or fax number

o *Data fields are required in PHIS import application• PHIS utilizes information to

exchange electronic messages between FSIS and Trade

Current Partial Data Feed

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Data Complete with Message Set

PG19 CBPG21 LOCAL BROKER CONTACT INFORMATION – FIRST NAME AND LAST NAME, LOCAL PHONE NUMBER, AND E MAIL ADDRESS – MARTHA STEWART 313-666-7777 [email protected] PG21 LOCAL BROKER FAX NUMBER IS 313-666-7771

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FSIS Data Grouping

The PGA Message Set accommodates the following “many-to-one” data relationships:

o Many inspection certificates to one entry• The PG 50 and 51 start and end the groupings• Multiple PG 14 (inspection certificates) may relate to the PG

13 (the foreign government that issued the certificate)

o Many lots within one inspection certificate• The PG 50 and 51 start and end the groupings• Multiple data lines providing specific lot information are

related to the PG 14 (inspection certificate)

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Foreign Inspection Certificates

o FSIS requires all imported meat, poultry and egg products to be properly certified by the competent authority in the exporting foreign country

o The electronic import application in PHIS uses a combination of information supplied in part from Trade and from the foreign inspection certificate• Currently PHIS receives official certification data electronically from Australia,

New Zealand, and the Netherlands*• For shipments certified electronically, when importers/brokers identify the

inspection certificate number through the PGA Message Set, FSIS PHIS will populate the import application based on the eCert data

o Filers making entries from countries that do not certify shipments electronically must provide additional PGA Message Set data identifying product attributes

*Note: FSIS will develop the capability to exchange official certification data electronically with other foreign governments

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FSIS Message Set Pilot

o The FSIS PGA Message Set Pilot began on April 27, 2014

o FSIS pilot has two Customs brokers actively participating:• A.N. Deringer, Broker Filer, Code 551• Barthco International Inc. dba OHL International, Broker Filer Code

OHL• Customs brokers participating in the pilot have the option to file

entries with or without the complete message set data elements

o Pilot entries are at three ports of entry:• Champlain, NY, Port Code 0712• Philadelphia, PA, Port Code 1101• Houston, TX Port, Code 5301

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o From April 27, 2014 through September 4, 2014, the two participating brokers in the FSIS pilot have submitted a combined 109 entries through ACE utilizing the PGA message set representing 4.5 million pounds of product under FSIS jurisdiction

o Entries filed are for product from Canada, Australia and New Zealand

o Product from Australia and New Zealand are interfacing with government-to-government inspection certificate data exchange (eCert)

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Message Set Entries by Import Country of Origin

Canada (A.N.Derringer)Australia (OHL combined with eCert)New Zealand (OHL combined with eCert)


o 87% of the pilot entries had no identified issues

o 13% of the pilot entries to date had identified issues

o Types of issues encountered:

o Data mapping both internal to FSIS and external to filer software use

o HTS conflict (1 entry)

Note: No identified issues delayed shipment movement or reinspection of product by FSIS. No data transfer issues from ACE to FSIS have been identified.

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FSIS Message Set Pilot (software validations)

o Automation of eCert pre-population of the application based on the PG14 record from the filer

• 42 entries submitted validated the success of eCert filings from Australia and New Zealand systems.

o Multiple inspection certificates (PG14) identified on a single entry

• 6 entries submitted with multiple certificate numbers and PHIS created separate applications based on the PG14 records as expected

o Increase shipment monitoring capabilities to prevent Failure to Present (FTP)

• PG 30 record facilitates FSIS monitoring

o Elimination of FSIS import inspectors to manually enter application data increases efficiency of reinspection process

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References

o Data Samples and Guidelines for Using the PGA Message Set for Electronic Completion of the U.S. Department of Agriculture (USDA), Food Safety Inspection Service (FSIS) Application for Import Inspection (FSIS Form 9540-1)http://www.fsis.usda.gov/wps/wcm/connect/98c45f3c-8a5b-47d7-9907-2fdc7352547f/Data_Samples_Guidelines_PGA_Message_Set.pdf?MOD= AJPERES&CACHEID=44196b9d-4fc1-45e0-a1de-eb3701385366

o Public Health Information System (PHIS) – Import Componenthttp://www.fsis.usda.gov/wps/portal/fsis/topics/international-affairs/importing-products/phis-import-component/CT_Index1

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FSIS Contacts

Bob Berczik [email protected]

Mary [email protected]

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EPA ACE Pilots:Looking for Volunteers

Consumer Product Safety Commission

Workshop on Electronic Filing

Bethesda, MD

September 18, 2014

Topics

• EPA-regulated commodities • What we are doing • What Trade can expect• Pilot programs• Trade Participation, Getting Started• Sample Message Set• Summary• Questions?

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EPA-Regulated Commodities

Under environmental statutes administered by EPA, six programs have import safety responsibility.

Pesticides (FIFRA)

Hazardous Waste (RCRA)

Toxic Substances (TSCA)

Fuels (CAA)

Vehicles and Engines (CAA)

Ozone Depleting Substances (CAA)

• Statutory requirements are built on risks to human health and the environment.

• Admissibility of EPA-regulated commodities are based on compliance to statutory requirements (reporting).

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What We Are Doing:eFiling, Automated Processing

Internet

ODS

Engines

Pesticides

Hazardous Waste

PRISM

Verify

ODSTS

WIETS

Importers, Brokers, & Carriers

Central Data Exchange (CDX)

CBP & EPA Import Data

Customs and

Border Protection

ACE Data Warehouse ACE/ITDS Single

Window

EDI

ABI Interface

ACE’s ESB EPA’s

Network Node

XMLEPA Staff

Streamline, improve reporting/processing of legal imports/exports

• Paper to electronic filing (Entry, Entry Summary Certified for Release, Simplified Entry/Cargo Release) –Partner Government Agency (PGA) Message Set, Automated Broker Interface (ABI)

• Validations to automate reviews for many EPA-regulated commodities

• Electronic status messaging – ABI messages (including errors and clearance)

• Updates, corrections – before arrival at, exit from ports

Goal: Early indication reporting requirements are met BEFORE cargo is loaded on a plane, truck, train, or ocean vessel.

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What Trade Can Expect:

• Shortened review/processing time from current paper filings (in some cases from days/weeks to minutes/seconds)

• Standardized filing process for EPA-regulated commodities at all Ports nationwide

• Eliminate duplicate reporting to EPA, CBP• Eliminate courier fees• Error responses for invalid filings to provide specific

information (data element level)• Ability to update and correct PGA Message Set filings

(future)

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Pilot Programs• Current pilots in production (April 30, 2014)

– Ozone Depleting Substances – Vehicle and Engine Declarations

Starting in ports of Long Beach and Newark

• Pilots planned for fall/winter 2014– Notice of Arrival for pesticide imports

Starting in ports of Chicago, Port Huron, Newark

– Hazardous Waste Exports (Spent Lead Acid Batteries) Starting in ports of Hildago, Laredo

• Get started now – PGA Message set samples, get going with software developers

Trade Participation• What you will do

– Create message sets– Submit Test filings to the Certification Environment in ACE– Receive, respond to Customs And Border protection (CBP)

notifications if needed– File in Production

• What you need to file (boiled down):– Ozone Depleting Substances (ODS): approved importer of record,

quantity– Vehicle/Engine Declaration: Data from forms 3520-1 and 21;

certification number– Pesticides Notice of Arrival: Data from form 3540-1; registration,

producer establishment number– Hazardous Waste Exports: Consent number 61

Getting Started

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• Are you an ACE Filer? Talk to your CBP Client Rep.• Are you filing these commodities at these ports? • Confirm participation.

– Current Pilots - Contact me and your Client Rep to get started.– Planned Pesticide Pilot - Respond to CBP-issued Federal Register

Notice (expected Fall 2014), contact me.– Planned Hazardous Waste Export Pilot - contact me.

• Work with EPA and your software developers. Begin identifying PGA Message Set adjustments to your software (EPA will work with you on examples).

8/28/2012 U.S. Environmental Protection Agency 63

Sample PGA Message Set1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 20 1 2 3 4 5 6 7 8 9 30 1 2 3 4 5 6 7 8 9 40 1 2 3 4 5 6 7 8 9 50 1 2 3 4 5 6 7 8 9 60 1 2 3 4 5 6 7 8 9 70 1 2 3 4 5 6 7 8 9 80

O I O F F M O S Q U I T O R E P E L L E N TP G 0 1 0 0 1 E P A P S 1 YP G 0 2 PP G 0 7 O F F M O S Q U I T O R E P E L L E N T P G 1 4 2 E P 8 6 9 3 4 0 - 8P G 1 9 E P N 0 1 2 3 4 5 C H N 0 0 2P G 1 9 C B S U P E R C U S T O M S B R O K E R A G E C O M P A N Y 5 0 0 E A S T 1 7 T H S T R E E TP G 2 0 1 0 0 N E W Y O R K N Y U S 1 0 0 1 2P G 2 1 C B J O H N S M I T H 2 0 2 2 3 4 5 6 7 8 J O H N . S M I T H @S U P E R B R O K E R A G E . C O MP G 1 9 I M B U G S P R A Y I M P O R T C O M P A N Y 3 4 5 N E WB E R R Y S T R E E TP G 2 0 2 0 3 B O S T O N M A U S 0 2 1 0 5P G 2 1 I M J A N E S M I T H 6 1 7 2 3 4 5 6 7 8 J A N E . S M I T H @B U G S P R A Y I M P O R T . C O MP G 5 5 N P C IP G 1 9 O V M A R I T I M E I N D U S T R I A L S H I P P E R S 6 0 0 P O R T R DP G 2 0 N E WA R K N J U S 2 0 0 3 4P G 2 1 O V J A Y S M I T H 4 1 0 1 1 2 3 4 5 6 J A Y . S M I T H @M A R I T I M E S H I P P E R S . C O MP G 1 9 D E Q S U P E R I O R S H I P P I N G C O M P A N Y 4 3 2 P O R T B O U L E V A R DP G 2 0 L A P U - L A P U C I T Y P H 3 2 3 4 0 2 4 8 6P G 2 1 D E Q J O H N R E Y E S 6 3 3 2 4 1 1 5 8 0 0 J O H N . R E Y E S @S U P E R I O R S H I P P I N G . P HP G 1 9 L G F A M O U S S T O R A G E A N D WA R E H O U S E 1 2 3 4 5 J E R S E Y A V EP G 2 0 N E WA R K N J U S 0 7 3 1 0P G 2 1 L G M A R K 6 6 3 2 4 5 7 7 8 3 3 M A R K . J I M @T I M E . C O MP G 2 2 9 4 4 C I E P 3 Y 0 2 1 1 2 0 1 4P G 2 6 2 0 0 0 0 0 0 0 0 1 0 0 0 O ZP G 2 6 1 0 0 0 0 0 0 1 0 0 0 0 0 B OP G 2 9 K G 0 0 0 0 0 0 0 2 8 4 5 3P G 0 2 C C A S 9 4 2 7 1 - 0 3 - 1P G 0 4 Y D E E T 0 1 5 3 7 5 7P G 0 2 C C A S 5 2 3 0 4 - 3 6 - 6P G 0 4 Y I R 3 5 3 5 0 3 5 0 0 0 0P G 0 2 C C A S 1 1 9 5 1 5 - 3 8 - 7P G 0 4 Y P I C A R I D I N 0 0 5 5 0 0 0P G 0 2 C P C 0 0 6 4 9 1P G 0 4 Y B T M O C R Y 1 F 0 0 2 1 0 0 0

Summary• EPA and CBP are testing in pilots

– Moving to eFiling, automated processing

• Need Trade volunteers to test – eReporting, early filing, messaging– Look for Federal Register Notice for pesticides pilot– Contact your Client Rep and me if you are interested

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For More Information

Roy Chaudet

Office of Information Collection

Office of Environmental Information

U.S. Environmental Protection Agency

202-566-1703

[email protected]


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Questions?

www.anderinger.com© 2013 A.N. Deringer, Inc.

Heritage of Trust Since 1919

CPSC - ITDS

• Introduction/perspective• Timing & resources necessary to participate in FSIS pilot

• ACE conversion• Software development• Testing

• Additional data fields• How many additional data fields required• Additional time required to process shipment

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One U.S. Government at the Border

September 2014

69 13th Term COAC 1 US Government @ TB

November 2013 Public Meeting Recommendations

Unified Filing of Entry Information Entry and PGA data sent well in advance of

cargo arrival CBP and PGA review data in advance of

cargo arrival, screening for data accuracy, importer & product compliance etc.

Clear PGA responses to filer at the line level Sound Risk Assessment methodologies

employed (prefer to use data not images). Document Imaging System used sparingly.


Trusted Trader Program Expedited clearance for known importers

Leverage CBP and Trade’s investment in C-TPAT, ISA or FS

Single Window Efficiencies Collect only the data required and utilize data

collected for other purposes for the PGA data whenever possible

Consider alternative method of identifying importers/exporters/foreign facilities – DUNS number?

Risk Assessment Methodology system must be robust, recognizing compliant importers, stopping high priority targets


Single Window Challenges Ability to timely obtain the right data from

the actual importer well in advance of cargo arrival

Key entry errors – they will occur! The more data required, (especially free form, not table driven) the greater the chance for errors

Management of data across all PGA message sets will be a challenge to the entry filer and the importer. Data creep is a major concern for the trade community

When data anomalies occur, immediate feedback to the filer must be given in form of message set, so data review and possible corrections can be made

72 Business Needs & Realities The Global Supply Chain is constantly evolving – legitimate trade should be managed as efficiently as possible

Non-resident Importers of Record are becoming more common.

Business to Consumer (B2C) shipments are increasing

Trade moves 24/7 – need the PGAs to make admissibility decisions well in advance of arrival to keep goods flowing.

Set High vs Medium vs Low Risk Priorities and perform post entry audits.

Staged implementation (similar to APHIS Lacey Act)

Be cognizant of the costs to delay and hold cargo

73 Keys to Success Vigorous Trade Participation in ACE

The more you test, the more you learn about the system, the process and the data requirements, and the more efficient the trade will become in managing the data.

Participation in PGA Pilots by Importers and Brokers who will be affected by the PGA message set for that Agency is critical to the success of the PGA Pilot. Data Quality Issues can be addressed

Mutual Understanding of the Data Requirements and Commercial Availability of the Data can be achieved

The Pilot is an important exercise to ensure the trade can produce the data efficiently and that the PGA has the legislative mandate to require it.

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Thank You

One U.S. “Efficient” Government at the Border

Is our GOAL!

CPSC Risk Assesment Model (RAM), CBP Automated Commercial Environment (ACE), & Pilot Programs

Business

Transcript of CPSC Risk Assesment Model (RAM), CBP Automated Commercial Environment (ACE), & Pilot Programs