The Top Ten Things to Remember as a Direct-Filer

Becoming a direct-filer of customs entries affords companies a much greater level of control of their supply chain and, if handled responsibly, a higher level of compliance with import rules and regulations. Aspiring direct-filers should review their current processes and supply chain and information flow while in test mode to ensure that they not only understand the critical touch points, but that they have considered and contemplated all necessary changes to support a direct-filing program. Depending on the size, volume and complexities of your import program, you might consider establishing a transition or conversion plan for the customs entries you intend to file directly.

As you move from test into a live environment please consider and routinely review the Top Ten Things to Remember as a Direct-Filer shown below;

The number one most important thing to remember when becoming a direct-filer…

1. Once live, someone must look at the system on a daily basis

The single most important thing to remember when direct-filing customs entries is that someone from your company must look at and react to changes in the system on a daily basis. This includes authorizing statements for duty payment, responding to error messages and to additional requests from CBP or other government agencies.

2. Review and authorize duty statements on a daily basis

It is absolutely imperative that someone review and approve pending duty statements on a daily basis. Do not rely on system warnings to prompt these actions. Failure to authorize duty statements on a timely basis will result in a Late File Penalty from CBP for every entry on that particular statement. Continued problems in this regard may result in a suspension of your direct-filing privileges or other enforcement actions by CBP.

3. Have back-ups and several cross-trained employees

All direct-filers should have multiple people trained on the system and capable of filing entries, authorizing duty statements and troubleshooting. At a bare minimum, we highly recommend that no less than two (2) people are fully trained and system competent; this allows adequate coverage for vacations and unexpected time off.

4. Respond to all CBP requests or system rejects timely

Occasionally CBP will request an electronic invoice (AII) or the actual hard-copy documents. These requests will come electronically in most cases. Please pay close attention to these requests and respond in a timely manner, failure to do so may result in a penalty action from CBP or an unfavorable change to the entry summary in question.

All system or entry rejects must be fixed or corrected until the entry in question has been accepted by ABI and CBP. Failure to correct entry rejects may result in a penalty from CBP or suspension of your direct-filing privileges.

5. Monitor and track your shipments

In some cases establishing a direct-filing program will necessitate closer coordination and more frequent communication directly with the carrier(s). For marine cargo make sure that you are receiving Arrival Notices and matching those to sets of documents from your suppliers. An Arrival Notice is your official confirmation that your consignment is onboard and they also contain important and necessary information (such as an I.T. number and date) to complete the entry summary.

6. Do not delete entries

Deleting an entry from the system should only be considered in extreme cases. It is also important to know that when you press the “Delete” button in the TRG Direct system that it only deletes the entry from your account, it does not delete it from the CBP ABI system. Once an entry has been transmitted, the only way to get it deleted from the CBP ABI system is to send a letter to the port where the entry was filed. Please consult the TRG Help Center or contact TRG Customer Service for further information and make every effort to keep the necessity to delete an entry to a minimum.

7. All entry information (except the port of entry) can be changed or corrected until the duties are paid

Every field on an entry can be amended or otherwise changed if necessary until the duty has been paid, except the Port of Entry. If you have opened and transmitted an entry in the wrong port of entry you will need to request that CBP in that port delete the entry from their system. Such requests can only be made by writing a letter. If you have not transmitted the entry yet, simply allow it to stay in the cue and replace it with information on a future shipment coming through that port. As long as the entry has not been transmitted it can remain on your dashboard waiting for replacement data for as long as you like.

All other information on the entry such as value, origin and quantity can be adjusted or amended until the duties have been authorized and paid. The entry becomes locked in the system after payment of duties and no further changes can be made. If amendments are necessary they must be performed using the port specific post entry correction process involving a Post Entry Amendment (PEA), Supplemental Information Letter (SIL) or Prior Disclosure.

8. Diversions require extra work

If an ocean shipment is diverted from one US port of entry to another, extra steps in the entry process will be required. Please consult the TRG Help Center or contact TRG Customer Service for further information.

9. Company name changes or banking changes require advance planning

If your company is changing its name or is changing bank accounts from which customs duties are paid through ACH, you need advanced planning for this event. Please consult the TRG Help Center or contact TRG Customer Service for further information.

10. You are limited and restricted in who you can file customs entries for

As a direct-filer you can only file entries for the company that employs you without having and activating a Corporate Customs Broker’s License. You are strictly prohibited and forbidden from filing entries for any other entity, other than the company that employs you (this includes, but is not limited to, wholly owned divisions or company subsidiaries).

Some other important things to remember when becoming a direct-filer are:

Estimates or guesswork has no place in the customs entry process (unless you are filing Reconciliation entries). If you are unsure of    information, work through the verification and validation process until you are 100% confident in the data. If the error was made by    your vendor or supplier make sure that you communicate with that vendor and correct the error for all future shipments.

If CBP changes or disputes a tariff number and you ultimately agree with their findings, make sure that you update the Parts File in    the TRG Direct system and any other spreadsheets you use to communicate HTS tariff numbers. Failure to adhere to the new    classification on subsequent shipments of the same goods as requested by CBP will result in a penalty action from CBP.

Convert or transition to direct filing at your own pace.

You will be assigned a CBP ABI Account Representative who can also assist you and provide guidance in the direct-filing of your    entries with CBP.

TRG Direct…smart, simple, direct.