U.S. Customs plans for the future, based on recent discussions within Customs as well as with the trade are based on two concepts:

1. treating importers as "accounts" to be rated for risk or trustworthiness and managed accordingly, and

2. tying in various Customs programs, such as the C-TPAT (the Customs-Trade Partnership against Terrorism), ISA (Importer Self-Assessment), ISF (Importer Security Filing--for sea shipments only) and FAST (the Free and Secure Trade Program--which relates to trucking goods from Canada and Mexico.)

It is likely that C-TPAT membership will be a pre-requiste for membership in other Customs-trade programs and will also serve to decrease "risk" and increase "trustworthyness" when an importer is rated as an account.

Currently, every entry stands as its own Customs transaction and there is no real link between the various Customs/Importer programs
Under consideration are implementation or revision of

Account Executive Program

Centers of Expertise

Risk-Based Account Management

Single Partnership Program

Simplified Entry Process

Simplified Financial Processing

These programs have not been implemented; what follows are ideas Customs is discussing. While deas are still being sorted out but is a taste of what you can expect in the not to distant future :

Account Executive Program: There will be different ratings given to members of the trade, from "High Risk" to "Most Trusted." The "most trusted" importer will be able to have a Customs "account executive" assigned to them, and would have their contacts with other customs personnel kept to a minimum. A "trusted" importer could also be assigned an "account executive" but we expect that their import programs of these will be closely reviewed, at least from time to time. Those believed to pose a greater risk will be pressured by Custom to revise their programs to increase compliance and security ratings, and those of this group who do not sufficiently revise their operations will possibly witness such chronic problems in obtaining customs clearance that their exiatence as importers will be threatened.

Centers for Expertise: Cusoms idea is to have centers for expertise as to particular industries. The aim is to assure uniformity of Customs treatment nationwide as well as to locate and target for closer scrutiny those industries or products where there is a greater risk for non-compliance. The degree of authority over the entry ports, assuming they are developed, could range from giving advice and assisting the ports to coordinate to giving then authority to order that specific action be taken.

Risk-Base Account Management: This overlaps somewhat with the Account Executive Program. It calls for the analysis of risks posed by specific importers, grading them, and monitoring compliance or progress in reaching acceptable levels of compliance, and assessing penalties as necessary.

Single Partnership Program: Customs would like to see a, expedited single procedure through which companies can apply for and participate in various Customs programs, such as the C-TPAT, ISA, and FAST. Customs is seeking better communications with importers and expedited review of applications for and acceptance into a single and multiple
Customs is considering

a. Acceptance into the C-TPAT would be a pre-requisite for acceptance into other Customs partnership programs.
b. C-TPAT and ISA would be combined into a single partnership program. Participants would have to be both C-TPAT validated and ISA approved before any benefits would be given out. In our experience, membership in ISA carries potential exposure and the promised benefits have not been significantly offsetting.
c. The importer could join one or several programs. C-TPAT membership would not be required for ISA but the processing of applications for both C-TPAT and for ISA would run concurrently. C-TPAT or ISA would be a required before consideration for other “partnership” programs.
Customs is exploring how it can work with other government agencies in the hopes of certifying importers so as to expedite release of cargo subject to restrictions imposed by such agencies as Fish & Wildlife, the Federal Trade Commission, and the Food and Drug Administration.
It is becoming increasingly apparent that without membership in at least the C-TPAT at the Tier II or Tier III level, an importer will be regarded by Customs as "one of them" as opposed to "one of us" and will face increased inspections and delays in cargo release.

Simplified Entry: Customs is considering ways to simplify the entry process in order to reduce the volume and redundancy of data transmissions, reduce the need to request additional information after entry, allow for statement-based processing for entry summaries and payments, and enable Customs to focus on higher risk importers, cargo and exporting countries. Three approaches are being considered:
a. Enhance the current unified filing of the ISF and entry to allow Customs to perform cargo selectivity sooner in the process and provide a importers with nearlier notice of cargo examination and cargo clearance. This would only be available to C-TPAT members for ocean shipments only. (ISF does not apply to air shipments. Cargo would still be subject to examination for admissibility requirements for laws/regulations administered on behalf of other governmental agencies but Customs hopes to make some arrangements with them.
b. Allow “trusted partners" to file entry summary data periodically, such as every 30 days. This program will not be implemented in the near-term as there are several issues that need to be addressed. In end, Customs wants a summary statement aggregating the value and quantities There would be no reduction in the data required for the entry summary. Customs would be looking to implement this in ACE (the “Automated Commercial Environment”) only and is proposing to make it available to ISA/C-TPAT members essentially as a pilot project. If the pilot program is successful, it could be made available to other importers.
c. Account based releases utilizing pre-filed or otherwise accessible information, with minimal information to be required at the time of at cargo release. The balance of required information would be filed with the entry summary, which is generally filed several days after release of the cargo. The pre-filed information could be posted in something like an ACE account profile and might consist of the importer name, address, and other unchanging data. The minimal data at release could be manifest data and possibly several additional information needed for Customs to determine admissibility. The ISF for sea shipments will still be required.,

Simplified Financial Processing: Customs is considering both short-term and long-term proposals to simplify financial processing.
Customs’ three ideas for the near term are:

a. Customs would allow importers to file an ACH application electronically and to initiate changes on the Customs web site.
b. Customs would modernize the Customs bill form (Customs Form 6084) by using a new paper form with a perforated bottom that can be torn off and mailed to Customs in a Customs-provided envelope.
c. Customs would s to post a listing of checks sent by Customs but not cashed on its website. This will alert importers and others of unclaimed or missing refunds due them.

For the long-term, Customs also is working on two ideas but cannot be implemented soon due to necessary interfacing with Customs “Automated Commercial Environment” (ACE) program:
a. Periodic Billing by E-Mail: Consolidated electronic bills for additional duties due for a grouping of entries would be issued periodically. Payments would be able to be made via ACH and perhaps by credit card. The liability for individual bills would be shifted to a single date after the issuance of the consolidated bill.
Customs hopes turn this into an electronic statement that would allow for the payment of estimated duties and receipt of refunds from Customs, with duties owing offset by refunds due.
b. Expanded Periodic Statement: Under this, Customs would extend the number of days in which importers must pay estimated duties. It would require payment of duties within 30 calendar days following the month in which the merchandise is entered. In order to reduce the risk of non-payment, Customs would also require a substantial increase in the amount of the bond from that it now it requires. Customs is also considering providing an interest bearing escrow account and staggering payment date for each importer. This project would only be available to “trusted partners.”

These ideas are in the development stages, but we expect that many will be implemented in the not too distant future.