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ACE and PGAs The Challenge to the Broker

The Challenge to the Broker | Amy Magnus


ACE Roll Out


• 2016 – the year of the roll outs • ACE Release Processing

• PGA Pilots

• PGA Mandatory Use

• Almost Reconciliation, Drawback, ACE Statement


ITDS


• From ensuring motor carrier safety to safeguarding against hoof and mouth disease, the 47 ITDS Partner Government Agencies (PGAs) currently slated for ACE integration, are as diverse as international trade is complex.

• PGAs represent ten cabinet level and four independent departments/agencies.

• Many PGAs are commonly known, others are less publicly visible.

• All are equally vital to keeping the commerce crossing our borders safe, secure and legitimate.


Brokers’ Preparation


• CBP and PGAs release CATAIR and Implementation Guides

• Brokers’ Software providers program ABI according to new specifications found in CATAIR and IGs

• Brokers test new upgrades, install, train, reach out to clients for additional data, pilot, and implement as the specifications are rolled out.


Myra’s IGs



Implementation Guides or ‘Myra’s Race to the Ream


• 47 Participating Government Agencies

• 15 Implementation Guides issued as of Aug. 31, 2016 • 1481 Pages of instructions

• 6 Appendices • 423 Pages of instructions

• 13 Agencies list more than one update • 41 updates total

• APHIS’ 8/29 IG is the winner in the Race to Ream (412 pages) - followed closely by FDA – 356 pages


2016 Mandatory PGAs


• DOT - NHTSA - National Highway Traffic Safety Administration

• FDA – Food And Drug Administration

• APHIS – Lacey Act

• NMFS - 370 - National Marine Fisheries Service – Tuna/ Tuna Products

• NMFS - AMR - National Marine Fisheries Service - Antarctic Marine Living Resources

• NMFS - HMS - National Marine Fisheries Service - Highly Migratory Species


PGAs Yet to Come


• APHIS Core - Animal and Plant Health Inspection Service

• ATF - Bureau of Alcohol, Tobacco, Firearms and Explosives

• CPSC - U.S. Consumer Product Safety Commission

• DDTC - Directorate of Defense Trade Controls

• DEA - Drug Enforcement Administration

• EPA - ODS - Ozone Depleting Substances

• EPA - PST - Pesticides (FIFRA)

• EPA - TSCA - Toxic Substance Control Act

• EPA - VNE - Vehicles and Engines

• FWS - U.S. Fish and Wildlife Service

• OMC - Office of Marine Conservation

• TTB - U.S. Department of the Treasury, Alcohol and Tobacco Tax and Trade Bureau

• USDA - AMS - Agricultural Marketing Service

• USDA - FSIS - Food Safety and Inspection Service


USDA APHIS Core Complexity


• Veterinary Services (AVS) • Live animals, related animal products and

byproducts

• Plant Protection and Quarantine (APQ) • Propagative material, seeds not for planting,

fruits and vegetables, cut flowers

• Biotechnology Regulatory Services (ABS) • Genetically engineered organisms

• Animal Care (AAC) • Live animals, dogs


APHIS DATA


There were a total of 1392 data elements within the various forms among APHIS programs that were converted to data.


Fish and Wildlife Complexity

• National Retail Federation drafted a letter to CBP on 9/7/16 detailing the following: • One member reported that prior to the pilot they had

40 HTS lines flagged, but under the pilot, they had 146 lines flagged. They went from 4,000 products to 14,000 products requiring F&W reporting.


F&W HTS 4 Categories

• FW2 • Requires extended data set (EDS)

• Contains animal products, but HTS isn’t detailed enough to make a determination (must submit a limited data set –N or Y, or an EDS)

• HTS is highly likely to require EDS (either a certified declaration that no EDS is required, or a full EDS is required)

• No HTS Flag – it’s the responsibility of the importer to “know” whether or not F&W applies




• May require data or a disclaim by “certifying individual”

• N1 Applies to certain wholly domesticated or extinct mammals.

• N2 Applies to certain mammals, birds and insects when they are of a domesticated source.

• N3 Applies to domesticated mice and rats for biomedical or scientific purposes.

• N4 Applies to U.S. Salmonids from a non-protected population when no salmonid certification is required.

• N5 Applies to Salmonids with a species country of origin other than the U.S. when no salmonid certification is required.

• N6 Applies to U.S. Salmonids from a non-protected population when a salmonid certification is required.

• N7 Applies to Salmonids with a species country of origin other than the U.S. when a salmonid certification is required.

• N8 Generic scenario applies to “other species” as appropriate.

• N9 Applies to all other salmonids when a salmonid certification is required.

• N10 Applies to mitten crab other than live specimens.

• N11 Applies to vegetable/human/wildlife combined products.

• N12 Applies to vegetable/human/wildlife combined products.




•F&W Applies – Require Data • Y1 Applies to certain mammals, birds, insects that are not

domesticated.

• Y2 Applies to domesticated mice and rats for other than biomedical or scientific purposes.

• Y3 Generic scenario applies to “other species” as appropriate.

• Y4 Applies to foreign origin salmonids that are protected.

• Y5 Applies to U.S. origin salmonids from a state where protected.

• Y6 Applies to protected fish species.

• Y7 Applies to protected mollusks.

• Y8 Applies to live mitten crab.

• Y9 Applies to vegetable/human/wildlife combined products.

• Y10 Applies to scenario N6 when trade cannot certify.

• Y11 Applies to scenario N7 when trade cannot certify.


Environmental Protection Agency Complexity


• Vehicles and Engines – off road

• Vehicles and Engines – on road

• Pesticides Notice of Arrival

• Ozone Depleting Substances

• TSCA Certification


Multiple PGAs in One File?


• One Entry of spare parts for autos- 911 Entry Summary Lines

• NHTSA – Parts subject to FMVSS, FMVTPS

• EPA - Vehicles and Engines

• EPA - Pesticides – Pumps for autos

• EPA - TSCA – Paint Pens and Fluids

• FDA - Radiation Emitting Devices – CD Players

• FDA - Medical Devices – Car Cover

• FWS - Leather Seats

www.anderinger.com © 2016 A.N. Deringer, Inc. | The Challenge to the Broker | Amy Magnus

PRE – ITDS Submission of NHTSA data


What is required to be submitted now


For one windshield, from one supplier, from one country


80 PGA lines



Contact Information


Amy Magnus, LCB, CCS, & CES

[email protected]

@amagnus

www.linkedin.com/in/amy-magnus-16237b12

mailto:[email protected]

http://www.linkedin.com/in/amy-magnus-16237b12





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