NCBFAA CLAIMS REDUNDANCE IN PROPOSED DATA IN CBP FORM 7501

The National Customs Brokers & Forwarders Association (NCBFAA) is encouraging Customs and Border Protection (CBP) to exclude additional data on CBP Form 7501 regarding steel and aluminum imports.

CBP Form 7501 is an “Entry Summary” document filed by a Customs broker with U.S. Customs and Border protection holding relevant information regarding the imported commodity, such as classification, origin, etc.

STEEL

CBP would require data ‘for certain HTS classifications of steel, the country where the steel used in manufacture was melted and poured (e.g., the original location where the raw steel is first produced in a steel-making furnace in a liquid state and then poured into its first solid shape).’

ALUMINUM

CBP would require data ‘for certain HTS classifications of aluminum, the countries where the largest and second largest volume of primary aluminum in the manufacture of the aluminum product was smelted and the country where the aluminum used in the aluminum product was most recently cast (e.g., the country where the largest volume of new aluminum metal is produced from alumina).’

Additionally, ‘the steel country of melt and pour and aluminum countries of smelt and cast for imports under those steel and aluminum HTS classifications subject to the Commerce Department’s steel and aluminum import license applications, and where applicable, the Section 232 steel and aluminum measures.’

NATIONAL CUSTOMS BROKERS & FORWARDERS ASSOCIATION OF AMERICA (NCBFAA)

Based on NCBFAA’s claims, the data is already obtainable by the Commerce Department through existing licensing programs. Including CBP’s proposed data could snowball into additional agencies following the same procedure, creating a more hectic entry and clearance process across the board.

The NCBFAA added further feedback regarding the duplication of the data in both paper and electronic format, stating that electronic methods would optimize efficiency and be more sustainable.

“The NCBFAA respectfully urges CBP to reconsider and withdraw its Notice for additional data elements in the 7501. The data already align with Department of Commerce licensing requirements. Further, it is vital for CBP to embrace electronic data submission methods, address system inadequacies, and foster enhanced communication between relevant agencies. By doing so, we can collectively achieve a modernized importation process that prioritizes efficiency, reduces burdens on the trade industry, minimizes data duplication and aligns with the goals of automation and green initiatives.”

Seth Renkema, Chief, Economic Impact Analysis Branch

U.S. Customs and Border Protection

SOURCE: U.S. CUSTOMS & BORDER PROTECTION DOCKET NO. USCBP-1651-0022 REVISION OF ENTRY COLLECTION INFORMATION

CBP originally delayed the new Entry Summary requirements “time for the trade to update their software programming and systems to comply with these new reporting requirements,” however, extensions ceased after May 10, 2023.