The Reconciliation Prototype
As part of Customs and Border Protection’s (“CBP”) transition from the Automated Commercial System (ACS) to the Automated Commercial Environment (ACE), there will be significant changes to post summary transactions.
The Reconciliation Prototype will transition from ACS to ACE on October 1. Changes to the program include:
- Simplified application – Only a reconciliation rider to the importer bond is required. If you are not a reconciliation importer currently but would like to become one, please contact Lauren Meyerowitz.
- Termination of blanket flagging option. For current blanket flagging participants, CBP will no longer blanket flag your entries as of October 1. If you would like all of your entries to be flagged for reconciliation, they will need to be flagged on an entry by entry basis. If you would like to instruct us as your Customs broker to blanket flag your transactions, please contact Lauren Meyerowitz.
- Post Summary Corrections (PSCS) must be filed prior to Reconciliation entries. Once an entry has been reconciled for any issue, it will no longer be possible to file a PSC to make additional corrections.
- Reconciliation filers will have to indicate to CBP if any underlying entries had Prior Disclosures filed on them. Moving forward, part of our filing procedure will including asking for your confirmation whether or not underlying entries were included in prior disclosures.
- The Centers of Excellence and Expertise (CEEs) will process reconciliation entries in addition to the existing thirteen reconciliation ports.
- There are no changes to the reconcilable issues, deadlines, or entry types:
- Reconciliation only applies to entry types 01, 02 and 06
- Reconcilable issues include value, classification (limited circumstances), and duty free treatment. The duty free treatment only applies to programs where the mechanism to make a retroactive claims falls under the 1520D Statutes.
- The deadlines for NAFTA Duty Deferral Type 08 (1520D) Recon Filings is 1 year from the import date
- The deadline for Value and Other Reconciliation Type 09 Recon Filings is 21 months from the entry summary date
Protests will transition from ACS to ACE on August 27, requiring filers to use electronic protests in the ACE Portal. As your broker, we will continue to handle these filings on your behalf.
If you have any additional questions, please do not hesitate to reach out to the manager of our Post Summary and Reconciliation Team Lauren Meyerowitz and firstname.lastname@example.org or 212-363-9300 x 124 or any member of our compliance team email@example.com