**Trade Support Network**

**Westin Hotel**

**Arlington, VA**

**Monday December 11, 2006**

**TRUCK MANIFEST SESSION 2:45 - 5:00 PM**

**Lou Samenfink, CBP**

**Francisco Jaime King,**

**Confederation of Customs Brokers Association of Mexico**

**Mr. Francisco Jaime King: "IMPLEMENTATION OF THE ELECTRONIC TRUCK
MANIFEST IN MEXICO"**

-   Unlike cargo movements from Canada to the US, Mexican cargo
    movements are usually brought across the border by a short haul
    transfer company rather than the long haul carrier that originates
    the move.

-   In most cases, Mexican Customs receives electronic information from
    the customs brokers.

-   99% of Mexican entry summaries are received at least one hour prior
    to arrival at the Mexican custom lot.

-   In a comparison between e-Manifest and Pedimento, the following
    groups of information are missing:

    -   Container/trailer box identification

    -   Carrier, vehicle, and driver information

    -   Hazardous materials identification

-   As of November 21, 2006, Mexican entries (Pedimentos) are required
    to include equipment identification and the UN dangerous goods code
    at the HS level. Entry summaries and duties are to be paid at least
    one hour before the vehicle arrives at Mexican customs, 30 minutes
    for certified companies.

-   As of March 1^st^, 2007, the carrier will be identified in a
    crossing manifest using a CAAT code (MX equivalent of SCAC).

-   As of March 31, 2007, companies that file periodic entries will
    transmit information similar to e-Manifest to MX customs one hour or
    30 minutes prior to crossing.

-   The vehicle and driver information will eventually be identified by
    a transponder and ID card (No date set).

**Discussion of the Mexican electronic manifest project**

-   Both the carrier and the broker can be penalized for incorrect
    information.

-   Mexican Customs issues the CAAT carrier code.

-   Changes can be made to Pedimentos. You do not have to cancel and
    resubmit, however the one hour pre-arrival clock restarts.

-   Consolidated shipments will have to be manifested as of March 31,
    2007.

-   Recommendation: Since drivers are often times not known until 10-20
    minutes prior to arrival, they should all be pre-vetted, registered,
    and issued ID cards. We need something more flexible than what
    e-Manifest is offering.

-   Recommendation: Drivers that have applied but have been rejected for
    a FAST card should be issued an ID card to use in a non FAST lane.

-   Nogales has already implemented a driver's card policy; you cannot
    get into the compound without a card, it is not an RFID readable
    card.

-   An individual thought that the Western Hemisphere initiative would
    solve this issue however it was stated that a passport does not
    require the same level of vetting as a FAST card or a Nogales import
    lot card.

-   If you have multiple brokers clearing cargo in one US to MX truck,
    "it gets complicated".

-   FMCSA will be receiving specific manifest data elements from
    e-Manifest; responses will be sent to the carrier.

-   Recommendation: Enable all manifest information to be submitted to
    CBP via the Entry Summary like the Mexicans.

-   Counter: The entry summary information is not always the same as the
    manifest information. CBP wants complete visibility.

-   Action item: Mr. Samenfink asked Mr. Santos to do a feasibility
    study on modifying the ABI HN record to capture manifest data.

    -   Post Meeting Addendum: Results of the feasibility study:

> MX Broker Proposal: Modify ACS ABI Cargo Selectivity HN Set
>
> After evaluation of the proposal to modify the legacy ABI Cargo
> Release "HN" transaction set, also known as Border Cargo Selectivity,
> the CBP Cargo Systems Program Office has determined that such a
> modification is not feasible due to the following reasons:
>
> 1\. In the ACE environment, the trade partner within or outside of the
> US, is provided three (3) methods for presenting truck manifest data
> to CBP. The party can use the secure ACE Trade Portal to enter the
> required information, the party can use the services of an ACE service
> center (a private sector entity, often a customs broker) or the party
> can create their own ACE eTruck Manifest application to interface with
> CBP, as many truck companies have already accomplished.
>
> 2\. The deployed ACE eTruck manifest system is the official CBP system
> of record for importations by truck and it is the existing ACE eTruck
> manifest application that is mandated under US Federal Law, as
> published in the Federal Register of the United States Government.
>
> 3\. To accommodate the electronic provision of the ACE eTruck Manifest
> data elements, functional processes, edits, validations, automated
> messaging and user interface presentation level displays through the
> legacy ABI Border Cargo Selectivity transaction set known as "HN",
> would require extensive technical modifications through the legacy ACS
> architecture, its applications and additional interfaces back into the
> ACE eTruck Manifest system that is the CBP system of record for cross
> border truck importations. Such a course of technical development
> would be extremely costly, time consuming, not efficient and not
> within the technical nor operational vision of ACE that has been
> approved by CBP and the Congress of the United States via the ACE
> program plan.
>
> For the above reasons, CBP will not modify the legacy Cargo
> Selectivity "HN" transaction set to be an alternative to the ACE
> eTruck Manifest application.

-   End of discussion of the Mexican e-manifest project.

=========================================================================

**Lou Samenfink led a discussion on the U.S. CBP e-Manifest program**

-   Mandatory e-Manifest filing has been announced for January 25, 2007,
    for the following states: Arizona, Washington, and select ports in
    North Dakota. There will be a period of informed compliance.

-   Current issues with Truck Manifest revolve around interfaces between
    ACE & ACS. Out of 124 Problem Tickets, some are considered "nice to
    haves" while others cause us real pain. We will publish this list on
    the CBP web site. Susan Maskell is working with the Internet team on
    using a list server to distribute PTR status. This could take 6
    months.

-   Kim Compton is the new manager of the Help desk. We are working on
    merging the ACE Help Desk and the Account Services Desk.

-   Jevon Jamieson: One of the largest concerns with e-Manifest is
    officer training.

-   CBP has supplied training and returned to many ports for additional
    training. Each port has a TSO (Trouble Shooting Officer) that should
    be relied upon. Early issues were that ports did not receive
    e-Manifests for a long period of time after deployment. However, in
    the case of Buffalo deployment, the second truck that arrived at the
    port already had an e-Manifest. A Standard Operating Procedures
    (SOP) manual will be distributed for standardization prior to
    mandatory. CBP will soon be posting an e-Manifest FAQ to
    www.CBP.gov.

-   Concern was expressed regarding anticipated delays when mandatory is
    enforced.

-   Lou: If the system does not work we will not back up trucks- we will
    work with you. January 25^th^ is not enforced compliance but
    informed compliance. Knowing who is in the cab is a major part of
    our job. ACE will make fundamental changes to the way business is
    done.

-   BRASS is a system that has run its course. However, to use BRASS in
    ACE you must establish better communications between the exporter,
    carrier, importer and broker.

-   Over 3,300 carrier Portal accounts have been established.

-   Over 360 carriers have established EDI connectivity.

-   Over 800 letters of intent have been received.

-   There are 23 software providers.

-   Processing times via the Portal are now quicker. It now takes 4-5
    minutes to create a one shipment manifest.

-   A shipper / consignee file has been established for Portal users.

-   A1 will deliver independent driver accounts so that carriers can
    share drivers more easily.

-   Although driver information is not part of the Trade Act and as
    such, you cannot receive a trade act violation, it is however,
    manifest information and you could receive a manifesting violation
    if incorrect.

-   CBP is looking at removing the trade act exemptions on in-transits,
    informals and empty trucks. To do so however, will take a Notice of
    Preliminary Rule Making (NPRM). This is not something that is
    planned for the near future.

-   Lou: We will post a cleansed version of the PTRs by the end of the
    week and a plain English version 6-7 weeks later. At a later date we
    will see about adding a description of workaround procedures that
    need to be followed prior to the fix being deployed.

-   If you get a rejection on an e-Manifest on January 25, you should
    still come to the border. At that time you will only receive a paper
    warning.

-   Concern was expressed regarding the concept of releasing ESAR in a
    "big bang" method.

-   A carrier has received a couple of dozen penalties for in-bond
    CF-7212s that are not being processed properly. Penalties have been
    received from Seattle, Laredo, and Buffalo for failure to export.
    Currently ACE does not support the ability for the carrier to report
    the export of a T&E or an I.E. This is not a PTR but a Change
    Request (CR).

-   Brokers are receiving penalties for not filing the entry summary
    timely. If the cause was because of ACE, then you should request
    mitigation. A comment was made that there is no way to prove that
    ACE was the cause. These penalties are coming from the entry team.

-   There are more urgent issues with ACS as for example, the Singapore
    free trade agreement has not yet been deployed in ACS. We are having
    problems with the HTS.