G/TFA/W/21  
 
6 February 2020 
(20-0928) Page: 1/4 
Committee on Trade Facilitation  Original: English  
 
US CARGO TIME RELEAS E STUDY PHASE TWO EX ECUTIVE SUMMARY  
COMMUNICATION FROM T HE UNITED STATES  
The following communication, dated 30 January 2020 , is being circulated at the request of the 
delegation of the United States for Members' information.  
 
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The WTO Trade Facilitation Agreement (TFA), Article 7.6, provides that WTO Members are 
"encouraged to measure and publish their average release time of goods periodically and in a 
consistent manner, using tools such as, inter alia, the Time Release Study of the World Customs 
Organization". Members are further encouraged "to share with the Committee their experiences in 
measuring average release times, including methodologies used, bottlenecks identified, and any 
resulting eff ects on efficiency".  
 
In light of TFA Article 7.6, and to share our experience implementing this Agreement, the 
United  States is pleased to provide this Committee with a summary of findings from Phase Two of 
its Cargo Time Release Study that covers Fiscal Year 2014 (1 October 2013 – 30 September 2014). 
This study established baseline trade facilitation performance measurements and helped to identify 
bottlenecks, inefficiencies, and other potential areas of improvement in the cargo release process.  
 
The US C argo Time Release Study was issued in two phases. Phase One, which outlines the intended 
parameters and approach to be undertaken in the study, was issued on 26 May 2015 and is publicly 
available.1 Phase Two of the Cargo Time Release Study (completed in De cember 2015) reported the 
results and conclusions of the study proposed in Phase One. A summary of these findings and results 
is being made available and shared in this communication.  
 
The US Department of Homeland Security (DHS) Directory for Science and Technology implemented 
this study in partnership with other key US Government agencies with border responsibilities. The 
study included analysis of goods arriving by sea, air, truck, and rail ports of entry. It excluded 
consideration of imports via mail, b ecause differences in import procedures for portal cargo render 
that domain unrepresentative. The study was highly dependent on data provided by US Customs 
and Border Protection (CBP) and partner government agencies that may hold cargo at the border.  
 
This study reflects the trade environment for the year it was published, 2015, and may not 
necessarily reflect the current trading environment and processes. There have been significant 
changes since then, including the implementation of the Single Window and the launch of the 
Automated Commercial Environment. As such, the data assessed in this study does not necessarily 
reflect the current performance of import processes. While the US Government is contemplating a 
new and updated study, those plans are still i n early stages and under discussion. We note that 
updated information about wait times at the border, release times, and metrics are available on a 
regular basis on the CBP website at https://www.cbp .gov/newsroom/stats/trade  for trade statistics 
and at https://www.cbp.gov/travel/advisories -wait-times  for passenger wait times.  
 
 
1https://www.ncbfaa.org/Scripts/4Disapi.dll/userfiles/uploads/DHSTimeReleaseStudyAnnex_Study_PlanMa
y2015.pdf   G/TFA/W/21  
 
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CARGO TIME RELEASE S TUDY – PHASE TWO  
EXECUTIVE SUMMARY  
The Department of Homeland Security (DHS), in partnership with other key agencies with border 
responsibilities, sought to complete a time release study (TRS), in support of Executive Order 13659, 
"Streamlining the Export/Import Process for America 's Busine sses". The purpose of the TRS is to 
measure the average time between the arrival of goods at the border and their release by the 
government. This TRS would establish baseline trade facilitation performance measurements and 
help to identify bottlenecks, ine fficiencies, and other potential areas of improvement in the cargo 
release process.  
 
This TRS includes analysis of goods arriving by sea, air, truck, and rail ports of entry. It excludes 
consideration of imports via mail, because differences in import proc edures for postal cargo render 
that domain unrepresentative. The TRS is highly dependent on data provided by US Customs and 
Border Protection (CBP) and partner government agencies (PGAs) that may hold cargo at the border.  
 
The most basic measure of time to  release is the difference between the arrival of cargo at a port 
and the release of the associated entry and removal of any holds. Most PGAs that are directly 
involved in the import clearance process operate through CBP or have their clearance as a 
requir ement of CBP entry release or removal of CBP holds. Therefore, data collected by CBP 
recording the actions of its customs officials generally suffice for calculating times for release in this 
fashion. Some elements complicate this simple model, requiring a dditional data collection, synthesis, 
and analysis.  
 
• Independent PGA activities. The PGAs with warrant to act independently of CBP 
complicate the above basic model, and their actions were thus accounted for through 
independent data collection. Therefore, t he study team collected data from five PGAs 
whose activities can affect the release of goods into commerce. Actions taken by these 
PGAs (US Food  and Drug Administration,  the Consumer  Product  Safety  Commission,  the 
US Fish and Wildlife Service, the US Food Safety and Inspection Service, and the 
Agricultural Marketing Service) as recorded by their data and by CBP, were incorporated 
into the time to release as endpoints in addition to CBP  actions;  
 
• Importer filing delays. CBP and the other PGAs cannot begin clearing cargo, even after 
it arrives,  if the proper  documents  have not been filed. If the importer  or broker  has not 
filed for entry, or if the carrier has not submitted manifest information, government 
processes cannot begin. These delays thus did not count toward the time to release. 
Therefore, the submission of entry paperwork and manifest documents count as alternative 
start points for calculating time to  release.  
 
There are also unavoidable complications that affect the precision of any estimate s gleaned from 
them. Data in many fields are entered manually, often hours after the action recorded took place. 
Some fields, in both CBP and PGA data, record only dates, rather than dates and times, which 
necessarily blunts the precision of estimates that  rely on these fields.  
 
This is the first -ever time release study conducted for the US Government. Therefore, CBP has 
never before collected data for this specific purpose. Instead, we are taking data used to support 
targeting decisions and ensure orderly collection of tariffs and duties and applying the data to a 
completely new use. Additionally, many of the missing data points involve activities that the 
US Government has no control over, like unloading of ships or movements in, out of, and around 
ports.  
 
Before now, CBP had no reason to collect these data, and those entities that do collect them (e.g., 
terminal operators, importers, stevedores) have proven reluctant in the past to share this 
information. To address these complications, some adjustments an d assumptions were made on 
the part of the study team. One of the most significant was that no attempt has been made to 
parse out unloading time, in -bond transit time, or warehousing time.  
 
Despite the fact that  the World Customs Organization recommends incorporating these time points 
into calculations of time to release, we lack reliable estimates of these times for any mode of transit 
and thus cannot reasonably include them in our study. Previous iterations of our methodology G/TFA/W/21  
 
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considered the possibility of estimating these times statistically from the data. However, in 
discussions with stakeholders, we have come to the conclusion that clarity in what the numbers 
represent is more important at this point than atte mpting to more closely hit an unknown target.  
While stakeholders would have liked the ability to parse out government from non -government 
delays, they seem to need real results whose origins others can trace. Subtracting out 
approximated delays would only complicate things further. We found that results could vary 
dramatically based on several factors outside the government 's control. Therefore, we broke our 
results down into the categories associated with these factors, as shown in figure ES -1. Results are  
presented by : 
 
• mode of transit;  
• whether entry documents were filed prior to arrival or not; and  
• whether the cargo was arriving directly at its port of entry, or travelled in -bond after arrival 
to its port of entry.  
 
Many shipments are released immediately upon arrival, or upon subsequent entry filing. Therefore, 
we further separated the results reporting into those shipments with no delay and those with a 
nonzero delay in order to present a more useful representation of the cargo for which some delay 
occurred. For shipments with a nonzero delay, we report the median, mean, and 90th percentile 
delay values.  
 
While these divisions of the results are extremely relevant, we recognize that this represents a 
somewhat complex answer. Therefore, we also present overall results, as shown in table ES -1. 
 
Table ES -1. Summary aggregate results  
Cargo  Percent of all cargo 
(by number of 
shipments ) Median  90%  Mean  
All imports  100%  0 hrs 20 hrs  15 hrs  
Air 38% 0 hrs 12 hrs  8 hrs 
Rail 4% 3 hrs 49 hrs  17 hrs  
Truck  31% 0 hrs 7 hrs 4 hrs 
Sea 27% 5 hrs 124hrs  39 hrs  
 
The median times listed above suggest that there may not be a great deal of room for improvement 
of government -managed cargo delays, based on the data elements available for this study. However, 
by looking at details of the more specific channels represented in figure ES -1 as well as some outlier 
analysis, this study may help the government to identify some potential points for improvement.  
 
A significant area for potential improvement is  in the data collection and database management. 
While we found the data provided to us to be a wealth of information, it was not collected for this 
purpose and so was not always able to reveal the answers to relevant questions. Some adjustments 
to how CBP  and the PGAs collect and store cargo data could improve the accuracy and ease of future 
studies. These adjustments include:  
 
• collecting date and time information for non -governmental  actions;  
• collecting  dates  and times  (as opposed  to just dates)  for certain key time points;  
• creating a direct link between in -bonds and entries or shipments within the 
automated targeting system  (ATS);  
• integrating vessel management system vessel arrival times into  ATS. 
 
The output of this report could be strengthened by conducting a year -over-year analysis using the 
same metrics, to assess longer -term trends. Deeper investigation into the causes of some of the 
more severe delays would also improve the overall understanding of cargo. The data collected for 
this report are quite rich and offer insights into more than just times of release. Additional study to 
leverage this data, updated regularly, and to investigate and visualize the contours of trade entering 
the country (e.g. what comes in how and when, whe re and with what value) could provide enormous 
insight into the nature of trade flows into the country.  
 
 G/TFA/W/21  
 
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Figure ES -1. Time to release results  
 
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