by Christopher Springer

The mission of the National Association of Foreign-Trade Zones (NAFTZ) is to help FTZ professionals stay connected, engaged and informed. So, it is not surprising that FTZ professionals are reaching out to NAFTZ regarding concerns over the scheduled migration of e214 core from ACS into ACE on September 16. In fact, they’ve asked NAFTZ to contact U.S. Customs and Border Protection (CBP) expressing concern about their ability to address and resolve these problems with no backup system available after September 16.

NAFTZ, motivated by a desire to frame a collective message from all of its software-provider members and broader membership, requested input regarding experiences with e214 testing.

Here is the essence of the response QuestaWeb sent:

QuestaWeb is a full suite ACE/ABI provider. For us, ACE Deployment G2 represents a turn into the home stretch of an endurance race that has lasted for more than a decade.

We have been testing the 214 and associated transactions in certification since CBP released the CBP and Trade Automated Interface Requirements (CATAIR) drafts. AMS, in-bonds and customs entries all directly associate with the 214 transaction, and all have been fully transitioned to ACE. We are fully committed – and prepared – to transition to ACE for e214 and ISF transactions on September 16, 2017. CBP also is fully committed to this transition and has established this date to assure that as many resources as possible are available to support the transition.

We have experienced an issue with filers who received CSMS #17-000536 on Tuesday, September 5, advising that testing is open to all trade participants. This announcement posed somewhat of a challenge, but the issue had more to do with the CBP certification setup than the transaction itself. Unlike entry filing, which requires a certification test, there is no requirement to test FTZ electronic transactions prior to going live. Consequently, most FTZ filers do not have a profile in the certification system, and the absence of a profile is resulting in a fatal error notice. On the CBP side, it is no small task getting a certification profile established. So, ABI reps have deferred to us, the software providers, to send their test transactions to certification.

Another challenge concerns the data in the certification database. Filers cannot send what they normally send to CBP’s production system to the certification system because the required information may not be reflected in the certification database. Bills of lading, zones and customs bonds may be missing from the certification system. CBP provides these particular data elements to mirror a production-like scenario. The same exact thing happened with customs entries, PGAs and all of the other transactions that have moved to ACE. Perhaps, only 5 percent of our filers sent test data for entries before transitioning to ACE.

Other than the FT (foreign trade zone) application ID and lack of record count in the Y record, the differences in the 214 transaction are negligible. Our approach to the transition allows the filer to choose whether the transaction will be sent in ACS or ACE format with a background configuration setting to default the transaction. Our code is 100 percent distributed to assure compliance for all of our filers as of this moment.

This challenge is just another issue in the move to ACE, and we must remember that the finish line is sight. We need to keep moving forward and maintain the momentum we’ve achieved to date.