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NAFTA's Alphabet Soup

NCAP, BRASS, CAFES ... it`s hard to keep up with all the acronym-laden initiatives that are designed to ease North American border crossings.

By Toby B. Gooley, Senior Editor -- Logistics Management, 9/1/2001

Governments have always been enamored of acronyms, those made-up names that are created from the initial letters of words. And no one, it seems, uses acronyms more than do national customs services.

Since the implementation of the North American Free Trade Agreement (NAFTA - an acronym that's become a household word in its own right), customs authorities in the United States and Canada have created an "alphabet soup" of programs that are designed to facilitate border crossings within North America. Few importers and exporters, though, know what those programs are all about. Here is a brief explanation - in alphabetical order - of some of the acronyms most often heard along the borders.

BRASS: The Border Release Advanced Screening and Selectivity program is an expedited release program available to high-volume, low-risk importers. An updated version of the former Line Release program, BRASS is designed to reduce congestion at land border crossings while freeing up inspectors to focus on less compliant shipments.

Importers must apply to participate in BRASS. Customs officials examine the applicant's compliance history and accuracy record. If approved, the importer receives a unique identifier called a C-4 code, which Customs provides in bar-code label format. The code includes information about the shipper, importer, entry filer, and the commodity being shipped. The bar-code label is attached to the international documentation, which the truck driver presents to U.S. Customs at the point of entry. When the inspector scans the bar code, the encoded data appear on his or her screen, allowing a quick decision on whether to release the shipment or hold it for inspection. BRASS is so popular, says John Considine, director of commercial processing for the U.S. Customs Service, that about 60 percent of inbound truck shipments from Canada move under this program.

CAFES: The Customs Automated Forms Entry System, launched in May as a pilot program at Port Huron, Mich., and Laredo, Texas, lets the Customs Service capture data without rekeying information from Customs Form 7512, says Betsy Durant, executive director of the Office of Trade Programs for the U.S. Customs Service. CF-7512 is the primary source of information regarding in-bond shipments.

Under CAFES, a two-dimensional (PDF-17) bar code with shipment information is attached to a completed CF-7512. When a truck arrives at a customs booth, the inspector scans the bar code. In just a few seconds, the information uploads to the Automated Commercial System (ACS), which responds with an "acceptance/release" or "rejection/hold for inspection" message. If no inspection is required, the truck can proceed without stopping at a secondary booth for further processing, and no manual data entry is required - welcome changes from the way in-bond shipments are processed now, Durant says. The same procedure applies when the shipment arrives at its destination and then departs the bonded facility, providing real-time verification that the in-bond transaction has been completed.

Although CAFES is brand new, users have already praised the program for its ability to reduce waiting time and paperwork. Says Sandra Scott, customs and trade advocate for Roadway Express, "The system is good, and it will be better when the paper CF-7512 goes away. But there's a lot of potential for using the two-dimensional bar code in in-bond movements. We're very excited, and we can't wait to implement this in other locations."

CSA: Canada's Customs Self-Assessment program, set to launch Oct. 29, is generating a lot of excitement in that country's importing community. Importers are optimistic that if approved, they will for the first time be able to obtain expedited release of low-risk shipments and self-assess their duties and taxes. Under the plan, they will be able to submit minimal data at the time of entry and periodically file full details later, rather than operate on an entry-by-entry basis. Post-entry audits will verify compliance levels and determine whether penalties should be assessed.

Other changes may not be so welcome, however. For example, Canada Customs will now have the authority to simply levy penalties instead of challenging violators in court. And the qualification process itself has become something of an issue. Not only the importer, but also the carrier and the individual driver must be approved for a shipment to cross the border under CSA, notes John Bescec, director, international trade for the Canadian Importers and Exporters Association. The application process, with its investigation of internal processes, information systems, and security, has been described by some as "grueling." As a result, he reports, few importers have qualified so far.

ITDS: The International Trade Data System will allow importers and exporters to submit a single data set for dissemination to nearly 100 U.S. government agencies. U.S. Customs is coordinating the project; initial participants include the Food and Drug Administration, the Federal Motor Carrier Safety Administration, and the Immigration and Naturalization Service. Roadway Express and customs broker Tower Group International successfully tested the Internet-based program; a pilot program began in Buffalo, N.Y., last month.

In its pilot phase, ITDS requires electronic filing of two sets of data prior to the truck's arrival at the border: a transportation declaration submitted by the carrier (the first time truck manifests have been automated) and a goods declaration, submitted by the importer or its customs broker. ITDS will take data from both, match them up, and distribute them to other federal agencies' information systems, Considine explains.

The beauty of ITDS, says Durant, is that "all the agencies will call a consignee the same thing, and we will all have the same definitions." Importers will no longer need to submit information separately to multiple agencies, and they will be able to clear multiple shipments at one time. ITDS also will allow participating agencies to determine a shipment's admissibility and whether enforcement actions are required prior to its arrival at the border. Once the shipment has been released, all parties will be notified electronically that the shipment is on its way, Considine adds.

There's a lot to like about ITDS, but there are challenges, too. "Having an automated truck manifest is a good thing," says Roadway's Scott. "The down side is that ... it's Web-based and our own internal information system can't transmit directly to ITDS." In this initial stage, carriers like Roadway that have EDI-based systems must re-key information into ITDS. That problem will be eliminated once ITDS has been incorporated into the Automated Commercial Environment (ACE), Customs' new information system that is now under development. In the meantime, Customs is considering an enhancement that would enable ITDS and, eventually, ACE to receive both EDIFACT X.12 messages and messages over the Internet.

ITDS presents a challenge for LTL carriers, in particular. It's impossible to segregate shipments by release type in an LTL operating environment. LTL trailers, therefore, may include shipments that are eligible for release under different programs. In order to use ITDS, though, all shipments on a vehicle would have to be eligible for release under that program. So BRASS shipments, for example, would require additional data input by the customs broker prior to arrival at the border or else the entire trailer would have to forego ITDS processing.

NCAP: The National Customs Automation Program is a prototype that demonstrates some of the paperless transaction capabilities that will be part of the ACE system. In place since 1998 at Detroit and Port Huron, Mich., and Laredo, Texas, only one (General Motors) of the five original importers involved in the test is still participating, a situation Considine attributes to insufficient federal funding.

NCAP, like BRASS, speeds up the release of cargo for highly compliant, low-risk importers. The importer transmits entry data to Customs prior to arrival at the border. The truck driver carries a manifest with a single bar code that covers up to 50 shipments. (Without NCAP, each entry must have its own bar code.) A transponder on the truck's cab transmits an identification code that relates the vehicle to the entries for the shipments it is carrying, Considine explains. Because the entries have been approved prior to arrival, the inspector can send the truck on after scanning the single bar code. According to Considine, General Motors officials estimate that NCAP saves them approximately $1.3 million in costs related to waiting time at border crossings. NCAP also includes a module that allows the importer to make duty payments electronically.

Carriers in all modes reportedly have expressed concern about two aspects of NCAP as it is configured today. The prototype requires carriers to funnel data through the importer's internal systems rather than directly to Customs. The importer therefore dictates which software is used and how carriers transmit data to its computers. Carriers also are required to obtain and transmit to the importer some data that are not normally available to them, which creates an administrative burden and makes them responsible for providing information that falls outside the normal scope of their operations. Although there is widespread support for the concept of a paperless release under NCAP, concerns over these and other issues make it certain that only some aspects of the program will be included in ACE.

All Roads Lead to ACE

At the moment, all of these programs feed data into Customs' ACS (Automated Commercial System) information system. But the immediate objective is to incorporate the most successful aspects of the pilots and prototypes into the critical ACE system, Durant says. "We need to take the best of all of these [programs] and consolidate them into the most efficient technology and the most advanced release systems that we can," she says. The plan is for the confusing "alphabet soup" to nearly disappear, absorbed into a single information system that encompasses all import and export trade and all modes of transportation, with ITDS as its "front end."

In general, importers in the United States and Canada support the aims of information management programs like NCAP, BRASS, CSA, and ITDS. No one could argue with the programs' goals - faster release of cargo, less paperwork, more efficient sharing of information among stakeholders, minimal requirements for compliant importers, and better use of Customs' resources. Nor would anyone dispute that the goal of creating single, streamlined information systems in both the United States and Canada - systems that can "talk" to each other - is sensible.

The success of such systems, says John Bescec, will depend on two things. First is harmonization of data and procedural requirements, not just within North America but worldwide, so that companies that do business in multiple countries can achieve real benefits from customs automation. And second, there must be clear, quantifiable benefits - not just added cost and administrative burdens - for importers participating in any of these programs. "Logistics departments have a difficult time selling senior management on the required cost investment," he says. "... It simplifies and streamlines things for Customs authorities, but industry bears the cost burden for it. They have to see a benefit."

Jim Phillips, executive director of the Canadian/American Border Trade Alliance, believes that neither the public nor the private sector will benefit from these programs until congestion at the U.S.-Canada border has been eliminated. In a speech at the Canadian Importers and Exporters Association's annual meeting, Phillips noted that although such programs speed up the approval of entries, congestion at border crossings essentially cancels out any time savings. "The current reality is that the least-prepared cargo carrier in each line dictates the waiting time and delay time of all pre-cleared carriers in line behind it," he said. "... [A] 45-minute wait to reach the primary booth to be processed in 30 seconds is ridiculous." He proposed that the United States and Canada create separate lanes for pre-cleared carriers and establish a system that would divert unprepared carriers before they reach the primary Customs booths.

All in all, says Bescec, everyone has the same objective: to get goods across the border as quickly and efficiently as possible and report the transaction accurately. That will indeed happen, he says, as long as stakeholders keep a healthy respect for reality while pursuing their lofty goals.

 

For more information &

U.S. Customs Today, the agency's monthly publication, occasionally includes articles about the land-border data-processing initiatives. U.S. Customs Today is available online at www.customs.treas.gov/custoday.

For a step-by-step description of how CAFES works, see www.customs.treas.gov/imp-exp2/auto-sys/cafes.htm.

Complete details on Canada's plans regarding CSA are available online at www.ccra-adrc.gc.ca/customs/business/importing/csa.

ITDS has its own Web site: www.itds.treas.gov. It's heavy on the technical details but provides a useful overview of the project.

An organization that keeps tabs on U.S. and Canadian Customs' information initiatives is the Canadian/American Border Trade Alliance. The non-profit group is devoted to facilitating trade between the two countries through improvements in operating standards, information sharing, and regulatory requirements. Find out more at www.canambta.org or call (716) 754-8824.

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