Production Stage of ACE 2.0 Might Begin in 2 Years. CBP Official Says

With Congress expected to ramp up its legislative work around the 21st Century Customs Framework in 2025 and 2026, brokers likely will start to see CBP's customs modernization work hit the ACE production environment in 2027, said Vincent Annunziato, director of the Business Transformation and Innovation Division within the Trade Transformation Office and CBP’s Office of Trade.

That's because "there is a dependency" between 21CCF legislation and CBP's modernization efforts. CBP is able to run pilot programs for its tests, "because we are getting voluntary data in order to do that," he said. But the "mandate" of 21CCF "gives us the ability to use all the pre-arrival data for cargo purposes, not just enforcement purposes, and it also ties it in to the non-traditional actors."

CBP is working to identify and secure sources of funding so development of ACE 2.0 capabilities can begin in FY 2026, according to an update released by the Commercial Customs Operations Advisory Committee ahead of its Dec. 11 meeting. "In 2025 and 2026, CBP will conduct limited production pilots that will serve as the bridge between the technology demonstrations and broad ACE 2.0 implementation, which is expected to begin no sooner than 2026," the COAC said.

CBP and the DHS Science and Technology Directorate’s Silicon Valley Innovation Program have tested or are currently testing global interoperability standards in five sectors: steel, pipeline oil, e-commerce, food safety, and natural gas, the subcommittee said. CBP and DHS's Silicon Valley Innovation Program had completed some testing in 2024 that focused on analyzing pre-arrival data and building transparent supply chains by developing digital twins, among other activities, according to the subcommittee.

As CBP continues work on ACE modernization, Annunziato said, brokers should continue to expect to have a role in conducting customs work.

“I can't tell you that your job won't change, because it will with this type of work, but I think it also makes you more important because when we’re getting this pre-arrival data, if something’s wrong or something’s not matching up, who are we going to go to?” Annunziato said. “That’s going to be the brokerage community.” Brokers may be needed to reconcile data, he continued.

“I remember the days when they were advertising, ‘automate or perish.’ I don’t think it’s that scenario. Today, we’re still going to have the legacy system in place,” Annunziato said. “But the thing is, ultimately, as your constituency wants better and safer ways to move stuff in and better ways to facilitate, especially with the [partner government agencies], this is going to be the road that you follow.”

Meanwhile, Annunziato also provided updates on CBP's international tests that it is planning to conduct in 2025. These tests would allow for the visibility and flow of trade data at the international level (see 2410090030).

One test will be on the Global G2G Data Exchange Network, which is “an automated framework based on traceable presentations, global interoperability standards, and immutable ledger technology that allows trade exchange among AEO partners,” according to a presentation slide prepared by Annunziato.

This test coincides with CBP’s Global AEO Customs Trade Partnership Against Terrorism Credential initiative, which Annunziato described in a presentation slide as an opportunity where CBP works with other countries to issue and exchange credentials in a globally interoperable manner.

“We’re working closely here with CTPAT. They’re doing a government-to-government exchange so that they can have automation that lets us know when MRA [mutual recognition arrangements] benefits are given to one company or another,” Annunziato said during the webinar. “This credential is very interesting because at some point we may be able to just issue a company the credential that says, hey, you’ve been certified by the U.S. or certified by Australia or the U.K., wherever it happens to be. And all you have to do is expose your credential on the supply chain, and they’ll determine whether or not you get the benefits.”

Another test that CBP may conduct in 2025 will be on an export/import program currently described as “My Export is Your Import.” This program will enable countries to exchange bill data to verify that goods have been exported, according to Annunziato. This program aims to reduce smuggling capabilities and expediting global trade, he said.

“‘My Export is Your Import’ is interesting. We may be changing this test a little bit because now there’s a lot of interest in a global single window, or international single window,” Annunziato said.

He continued, “Another big outcome of this is if somebody did an examination overseas and we want to then use that as a reason to lower the need for us to examine something on our side, we could do that as well. ... I can tell you that the system that we're building is very strong on facilitation.”