September 20, 2012
Re: CHINA SHIPPING To Switch from AMS to ACE
Advanced Manifest Filing and related Electronic Data Interchange message reporting with US Customs and Border Protection (USCBP)
On Tuesday morning, September 25th, 2012, China Shipping Container Lines and its agents and offices are scheduled to switch from the expiring “AMS” advanced manifest filing system to US Custom’s new Automated Commercial Environment “ACE” protocol
andfiling system.
This change in protocols and filing system by the carrier should have little or no effect on most importers and vendors doing business with China Shipping.
Features of the change, and projected functionality of the ACE system and related computerization improvements in process at USCBP can be accessed on the
pertinent US Government website:
With this change, US Customs’ overarching purpose is to bring all multi-modal manifest entry, amendment and handling processes into a single platform to facilitate homeland
security functions, allowing:
- all participating government agencies concerned with cargo and logistics to more easily access and use a single system for their respective oversight
functions;
- all carriers (sea, rail, air, truck) and their agents and business partners (NVOCC’s, ocean transport intermediaries, importers of record) to use and access the same platform and related databases for import and export cargo manifest filing and related functions, replacing multiple
unconnected platforms and protocols previously used;
- enhanced reporting and recordkeeping functions in ongoing efforts to perform the primary USCBP and DHS functions entrusted to the agency.
The deadline for ALL carriers, NVOCC’s and brokers to switch to the ACE system for manifest filing and customs clearance is September 29th, 2012. All customers should already have contacted their US agents, customs brokers and business partners to ensure that they are in compliance with the regulations and are filing
through ACE goingforward after that date.
There may be some changes in functionality in the future as the ACE system continues to be rolled out, but these are not germane to the initial implementation of the ACE protocol by China Shipping announced here. The vast majority of changes to the carrier’s manifestfilings are purely technical and will be invisible to China Shipping’s business
partners.
ACE system changes to advanced manifest filings, acceptances, clearances and related
cargo processes include the following:
1. Customs Holds and Releases possible at container level later in 2012.
CBP will be able to place and remove holds at several points in the logistics custody chain at the conveyance, master bill of lading and, sometime in the near future, at the container level. When this becomes effective, this may effect the ability of the carrier to proceed with oncarriage and release of containers not affected by a hold (e.g.: containers which are in no way connected with the freight being held for challenge or inspection under any carrier or NVOCC bill of lading for which a hold has been issued). This functionality has not been used to date with regard to sea manifests, and will be subject to test and development prior to implementation by all carriers. At this time, all hold and releases received for any master bill of lading and any container listed under that master will constitute a hold or release on all cargo represented on the master bill of lading. China Shipping will advise when and ifseparate holds and releases by container
alone will be offered, tested and implemented with the direction of US CBP. Customs has advised that this will follow sometime after the ACE mandatory filing compliance date of Sept. 29th, 2012. At present, the carrier’s release of cargo will continue to be granted only on the basis of “master bills of lading”, pursuant to satisfaction of freight obligations and release of all containers on the pertinent master or direct bill of lading.
2. Hold notices will show the name of the US Government Agency issuing the hold.
ACE (unlike AMS previously), will inform carriers as to which Participating Government Agency (PGA) has held or released cargo. China Shipping North America will forward this enhanced data through usual channels via EDI and/or internet product (I Scope) query related to bill of lading and cargo status data.
3. ACE extends Broker download of manifest data to sea manifests(unlike ABI previously).
China Shipping expects to see communication improvement between all parties to
shipment due to better information sharing, and is unaffected by this change.
4. ACE increases the number of possible secondary Notify Parties on master bill of lading entries (including terminals, hauliers, agents, etc.) to 25. China Shipping will not expand the total number of notify parties for its master bills of lading, nor for NVOCC bills of lading which it files through ACE at this time, but Self-filing NVOCC’s are welcome to use this function
in their filings directly with USCBP.
5. ACE allows carriers to create list of trade partners who are authorized to use their type two custodial bond through the ACE Portal, i.e. In-Bond Authorization. At the time of start-up, China Shipping will make no change to its current practice of only authorizing certain railroad carriers to use our custodial bonds for cargo on-carriage in limited cross-border situations. China Shipping has no plans to extend such blanket authorization for use of its Customs type 2 custodial bonds to any other vendor as against corporate interest.
6. ACE requires carriers to create and maintain sea conveyance information through the ACE Portal. China Shipping (CSNA) has updated all of CSCL’s owned, leased and shared vessel information into the ACE Portal.
7. ACE system will send a status notification to Carriers and subsequent Notify Parties such as Port Authorities when a Paperless Master Inbond (IT, T&E, IE) has been deleted by a carrier.
This should have no effect on China Shipping’s cargo services.
8. Changes to “in bond” inland transit filing processes:
a. Previously, if an importer wished to have cargo clear at an inland location on a through-bill of lading, the carrier would transmit a simple “IT” (inland transit) notification to that effect, or a cancellation of same, and receive only an acknowledgement of receipt from Customs. Under ACE, the “IT” or other in-bond movement is filed as a request for inland movement under the carrier’s bond, and receive a permission for the “IT” or other in-bond movement (e.g.: “T&E”, “IE”) in order to move the cargo inland from a bonded pier. Any amendment to an approved “IT” is likewise subject to a request for permission which must be granted for any change to the IT to be acted upon. In practice, China Shipping expects to see little change to current processes, but merchants and brokers should be aware that the new process gives Customs another chance to review, target and potentially hold cargo for inspection in the event that diversion or IT cancellations prove of interest to authorities. CSCL will under no circumstances move cargo under its custodial bonds unless proper permission is received from USCBP. No change in data format or business process is expected for the vast
majority of cargo to be imported on routes employed by China Shipping.
Customers are forewarned that failure to provide clear inland IT destination and other critical Bill of Lading data in shipping instructions to the carrier prior to lading on board at origin may result in added delays/holds if amended after initial cargo acceptance by USCBP.
b. Previously, certain in-bond inland movements were subject to the need to provide hardcopy bond application (i.e., for T&E and IE applications), which are slated to become completely paperless transactions under ACE. The precise workings of these (rare) filings for inbound movements can only be worked out in practice in the months following ACE implementation. China Shipping expects that the processes will be slightly improved after all parties become more familiar with requirements in the field, but these bonded filing
types remain relatively rare for cargo imports. For your information: regarding T&E filing only, CSCL will advise that all T&E cargo is subject to FDA/BTA consideration without exception.
9. ACE provides for new reports via the ACE web portal for carriers, brokers and importers.Consult your broker or the CBP website above mentioned for more details.
As always, China Shipping Customer Service is ready to answer any questions you may have as regards the ACE transition. Thanks for your attention and support.
Regards.
China Shipping NA Agency Co., Inc.
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