|Date: February 18, 2016
Subject: U.S. Importers Should Prepare for New Buyer Reporting Requirements Under ACE
|On March 31st, 2016, U.S. Customs & Border Protection (CBP) is scheduled to begin the transition to its new ACE environment. This transition will ultimately result in the discontinuation of CBP’s legacy Automated Commercial System (ACS) system and some related processes. The new ACE environment will present material changes for U.S. importers and other parties.
Under existing ACE data requirements, entries consisting of individual shipments and multiple buyers (‘multi-buyer’) will now require the federal tax ID number to be reported for each buyer if:
In the current ACS environment, the name and address for each individual buyer/consignee can be reported to Customs for entry purposes without reporting the federal tax ID number.
As an example, on or after March 31st, 2016, if a multi-buyer shipment to the U.S. consists of 10 individual US$1,000 shipments under a single entry (release), the Federal tax ID number for all 10 buyers must be reported to customs prior to the freight entering the U.S. per the conditions above. Failure to do so would result in the freight being denied entry until the information can be provided.
If the multi-buyer shipment represents an aggregate entry value less than US$2,500, the name and address for each consignee may continue to be reported in lieu of the federal tax ID number. Where the goods have not been sold at time of entry into the U.S., the federal tax ID number for the consignee (e.g. warehouse) may be used for entry purposes.
Parties are encouraged to review this information carefully to minimize possible disruptions or additional costs. CBP has stated that they are reviewing this new requirement for possible modification prior to the implementation of the ACE environment, however, no such changes have been communicated at this time. An update will be provided should new information become available.
For additional information on ACE, please contact Delmar’s U.S. Advisory Services practice in Champlain, NY. Additional information regarding CBP’s ACE initiative may be found here.