CSMS Message: 94-001246

Title:INCLUDE ALL LINE ITEM INFORMATION FOR CARGO RELEASE
Date:1994-12-12
To:abi
Links:previous, next

IT HAS COME TO MY ATTENTION THAT MANY ENTRY FILERS BELIEVE THAT IT IS
OK TO NOT CLASSIFY ALL LINE ITEMS AT THE POINT OF CARGO RELEASE.
SPECIFICALLY, SOME BROKERS BELIEVE THAT ON ENTRIES WITH LOTS OF
INVOICE LINE ITEMS, ONLY FIVE HAVE TO BE CLASSIFIED. THE REST...WELL
THEY'LL TAKE CARE OF IT AT ENTRY SUMMARY TIME. WELL, THIS IS EXACTLY
WHAT THE TREASURY INSPECTOR GENERAL'S OFFICE SAID WAS WRONG WITH OUR
PAPERLESS CARGO RELEASE PROGRAM. CUSTOMS WAS LAMBASTED FOR RELEASING
CARGO AS PAPERLESS, WHEN IN FACT, A FULL DECLARATION (INCLUDING ALL
CLASSIFICATIONS) WAS NOT PROVIDED.

THE ONLY LOCATION WHERE WE DO ALLOW PARTIAL CLASSIFICATIONS, IS AT THE
NORTHERN BORDER, WHERE WE DO NOT ALLOW PAPERLESS FOR DIRECT ARRIVAL
ROAD AND RAIL FREIGHT. EVENTUALLY, THE NORTHERN BORDER WILL COME
UNDER THE SAME RULES AS EVERYONE ELSE.

IT IS RECOGNIZED THAT SOME ENTRIES ARE DIFFICULT TO FULLY RATE AT THE
TIME OF CARGO RELEASE. HOWEVER, OUR POLICY IS VERY SIMPLE. IF YOU
ARE GOING TO CLEAR CARGO WITH A 3461 EITHER ELECTRONICALLY, OR ON
PAPER, ALL LINE ITEMS MUST BE PRESENT, INCLUDING THE CLASSIFICATIONS.

WE HAVE NO WAY OF KNOWING IF OUR PAPERLESS RELEASES ARE VALID, IF
ENTRY FILERS BELIEVE THAT THEY CAN CLASSIFY WHAT THEY WANT AND FORGET
THE REST. PLEASE BE ADVISED, THAT WE HAVE A SIMPLE MECHANISM TO
PROHIBIT A FILER FROM RECEIVING A PAPERLESS RELEASE AT THE DISTRICT OR
NATIONAL LEVEL. IF WE DETERMINE THAT AN ENTRY FILER IS CONSCIOUSLY
NOT REPORTING LINE ITEMS FOR CERTAIN TRANSACTIONS, WE WILL HAVE TO
CONSIDER REVOKING PAPERLESS PRIVELEGES. THIS IS AN ACTION THAT WE
WOULD TAKE AS A LAST RESORT, BUT THAT WE WILL TAKE IF WE ARE FORCED TO.

SINCE PAPERLESS CARGO RELEASE PROCESSING BEGAN IN 1988, ABI
PARTICIPATION FOR CARGO RELEASE PURPOSES HAS INCREASED TREMENDOUSLY.
OBVIOUSLY, THE ABILITY TO EFFECT CARGO RELEASE WITHOUT THE
PRESENTATION OF A 3461 IS A TREMENDOUS BENEFIT TO CUSTOMS AND THE
IMPORTING COMMUNITY. THE VAST MAJORITY OF TRANSACTIONS CONTAIN A FEW
NUMBER OF INVOICE LINES. SHOULD WE JEOPARDIZE THE ENTIRE PAPERLESS
PROGRAM FOR A HANDFUL OF TRANSACTIONS THAT REQUIRE EXTRA EFFORT AT THE
POINT OF RELEASE?

LOU SAMENFINK 202-927-0510