With the processing of reconciliation entries transitioning to ACE on February 24, 2018, we wanted to let our readers understand the practical results.  For instance:

  • ACE will be the sole mechanism to file Reconciliation entries (even if the underlying entries were filed in ACS)
  • Importers may choose the port in which to file
  • CBP will no longer blanket flag an importer’s entries for Reconciliation.  Self-filing importers, as well as those entries processed by a 3rd party broker, will need to be flagged individually.
  • You cannot file a PSC to adjust an entry to be flagged for Recon.  The only recourse is to request that CBP flag your entry retroactively.  This request must be made within 60 days of liquidation.
  • Importers indicate whether any of the underlying entries in a Reconciliation entry were subject to a prior disclosure
  • No-change Reconciliations will only need to identify the underlying entry numbers and original entered values, duties, and fees not being reported for aggregate or entry-by-entry Reconciliations.

CBP will also no longer provide the MasterFile Extract and Liquidation Extract Reports to importers that provided detail on entries flagged for Reconciliation. Importers may utilize ACE reports to identify those entry numbers going forward. For an unknown limited amount of time, ITRAC reports will also still be available; though it is likely they will be discontinued as well.

While we look forward to certain aspects of CBP’s transition of Reconciliation entries to ACE, such as the elimination of reporting of original values, duties, and fees, there are some aspects of which we are wary. In particular, because CBP can no longer blanket flag entries and will only grant retroactive requests to flag at its discretion and for a limited amount of time, it is very important to both trust and monitors your customs brokers’ entry flagging.

Importers can work with their customs brokers to enact a blanket flag, just as CBP had been doing, or if they had been entry-by-entry flagging, work with their customs brokers to mimic the conditions for which they had been previously flagging their entries. Additionally, given the glitches, we have seen when other programs have transitioned to ACE, and the fact that many Reconciliation entries are due in October, importers, and CBP should allow ample time to sort things out before the first Reconciliation due date arrives.  Read more here.

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