Role of RLF in ACE Still Being Considered, Says CBP's Smith
LAS VEGAS -- The place for Remote Location Filing within the virtual Automated Commercial Environment (ACE) is yet to be decided at this point, said Brenda Brockman Smith, executive director of the ACE business office at CBP. Smith, who spoke at the National Customs Brokers & Forwarders Association of America conference on April 9, also said she expects the agency to add some Food and Drug Administration (FDA) elements to the system before CBP begins to require all trade filing in ACE.
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Asked about the role of RLF within the system, Smith said "I don't know yet."The virtual work within the Centers of Excellence and Expertise (CEEs) has shown that some processes no longer need to be tied to a geographic locations, said Smith. After thinking about the CEEs, possible changes to customs broker permitting and the idea behind RLF, it seems "they are really all headed in the same direction," she said. That is, "you don't necessarily have to be in one geographic location to be able to file or manage a particular entry. If you come to that conclusion, you recognize you have a lot of opportunities. I think we haven't, from a policy perspective, figured out exactly which way to go with those opportunities, but my belief is ACE can do however we want it to work, so from a technology perspective, we are looking to make the system as flexible as possible."
CBP expects to include some FDA elements within ACE in coming months, well before the November 2015 deadline for mandatory use of ACE for cargo release said Smith. "We have been working very closely with FDA to lay out their plan," she said. "At this point, if things go well, you should be able to start seeing FDA capability in the late winter, early spring next year. That's the penciled in plan at this point." CBP is now working on Lacey Act capabilities and may be able to add those earlier than the scheduled goal of January of 2015, she said. While ACE will be mandatory for all CBP cargo filings as of Oct. 1, 2016 the Nov. 1, 2015 deadline is "the key date" and 90 to 95 percent of the transactions that CBP receives will be subject to that requirement, she said.
After the 2016 deadline for all filers to use ACE, CBP will continue to look at and update its system in response to industry needs, said Smith. The "agile" approach for ACE software development, using smaller incremental parts of the system to add flexibility, is not a "panacea," but it will allow the system to be closer to what is actually needed at the time a piece is deployed, she said. That's been a problem in the past development of ACE, she said. One issue in moving quickly on ACE is that CBP personnel at the ports can be behind in some cases, Smith said. "One of the great things about agile is that we move quickly," she said. "One of the challenges to the agile approach we move very quickly." The training that CBP uses, which includes paper manuals and screen shots, is appropriate for the software built by CBP five to ten years ago, she said. It may be more useful to make available videos and webinars for training on the subject," said Smith.