NCBFAA Customs Committee

080123 v.1.0Data edits for entry will not be affected in the ESAR drops. The question was raised howwill the edits operate when cargo release is certified from entry summary. The answer givenis that notwithstanding certification is made on the entry summary, cargo release (entry) andsummary take different system paths.RLF Uniformity (J.Peterson)At the Customs Committee September 26, 2007 meeting a work group was formed tosupport Angela Downey in her efforts to improve this NCAP test for customs brokerperformance and RLF utility. CBP agreed to participate in the NEI Third Thursday programwith an RLF installment, to draft an informed compliance document, and to look atestablishing an actual use tariff listing while seeking an electronic solution to documentaryrequirements. John Peterson will update the Customs Committee on progress since ourSeptember meeting, and near term plans for this project.Ken Bargteil appointed John Peterson, Amy Magnus and Elisha Vasquez to the RLFWorkgroup with its mission to support Angela Downey in her efforts to improve customsbroker performance and RLF usefulness in this NCAP test. John Peterson reported that in theinitial meeting Angela Downey was amenable to making RLF more encompassing. Theability to remove RLF entries from statement was also on the agenda. There is presently noprescribed and recognized method for doing this. It sometimes works to contact the RLFcoordinator at the port of entry and request that they remove the entry, but some resist doingthis because it creates extra work for them and it requires submitting paperwork. JohnPeterson believes that this is critical for brokers, and that a solution must be found. As withother issues in RLF, the challenge is to avoid paper records.Another goal for this engagement includes the removal of restrictions on ADD/CVDentries and entries involving documents such as CITES permits that are not really filed withCBP. One problem CBP wants to resolve is that they frequently don’t know who to contact ifthe need arises on an RLF entry. This might be accomplished by devoting a data field tocontact name and phone number. CBP also identified incomplete and/or inaccurate AIIinvoices as an intractable problem. CBP requires that AII duplicate the commercial invoice,including all, rather than minimum or selected data from the invoice. John Petersonsuggested that a good start could be made if NCBFAA would impress upon its members thatthe AII is supposed to be a mirror image of the actual invoice, line for line, with descriptions.A follow-up meeting has been scheduled for next week by teleconference. CynthiaWittenburg has been appointed as Branch Chief for Entry, including RLF.There was general agreement from everyone on the conference call that a good start hadbeen made. CBP recognizes that training for import specialists, RLF coordinators andofficers in the field is necessary, and we recognize that information and training for ourmembers is also necessary. Angela Downey and Cynthia Wittenburg will meet with theirstaff at CBP HQ to go over the agreed issues, and John Peterson will continue report onprogress to the Customs Committee Chairman. This will allow the entire Customs Committeeto remain engaged on this important issue.Ken Bargteil informed the Committee about a warning letter received from CBP inCleveland taking note of an entry that should not have been filed RLF because it includedgoods subject to antidumping duty. The warning letter went on to threaten revocation of RLFprivileges in case of another such mistake. Ken Bargteil characterized the letter asrepresenting the height of arrogance for an agency that makes mistakes every day, but sees fitPage 6 of 6