There is a controversy brewing in the U.S. Customs Brokers community as it relates to the future paperless use of ACE (Automated Commercial Environments) and the national versus established regional approach to clearance.
   There are significant downsides for the broker community and ultimately their customers, including unintended consequences.
   As a friend to the U.S. Customs Brokers from our earliest days of publishing Air Cargo News starting in 1975, when we delivered ACN to the fabled Cargo Building 80 at JFK International Airport—“home of the customs brokers”—we present Donna Mullins from Georgia, who takes the brokers’ side four square.
   We welcome your comments.

Currently in the U.S. Customs Brokers business, the subject of permitting is surrounded in confusion.
   To put it simply, the current system provides for both district permits and a national permit.
   Until now, most customs brokerage firms have found it necessary to have both.
   The national permit allows for remote location filing, and for firms that want to file in multiple districts, district permits were needed for entries that could not be filed RLF.
   That is what stands for “keep it as it is,” but that is not possible.
   Soon, very soon, in less than two years the district permit will become a wholly irrelevant artifact in the regulations.
   As ACE moves toward completion, there will be no entries that cannot be filed RLF.
Customs brokerages will be able to file at all ports for all types of entry on the basis of a national permit.
   That is the inevitable end state of the “as is” situation.
   Without some change to what is on the books, by November 2015 a customs brokerage firm will be able to operate nationally on the basis of one permit and one individually licensed customs broker.
   That will be the benchmark for permits.
   The question is, how well does this “as is” condition serve our profession, our members, the individually licensed customs broker, CBP, our importer clients, the American consumer?
   What will it mean to these stakeholders when all that is required by law and regulation to offer national customs brokerage services is a single permit supported by a single licensee?
   Many of our industry members are making the transition to ACE summary-filing now, and some are piloting ACE release.
   Many are finally realizing (and enjoying) the true paperless environment as we send more and more of our summary packages through ABI using CBP’s document imaging system.
   As more ACE functionality rolls out, we will soon be filing RLF for all our entry types, and with the promise of ITDS, almost no paper documents will be required at any local port.
   The future of our industry has already changed, and now it’s time to consider what structure will be needed to support this future.
   The “as is” structure is geographically based, and while business needs may drive the need for local offices in certain places, in our new virtual future, there is no need for a local office solely to file entries that will be electronically routed to specific CEEs, which could be anywhere in the country.
   Brokers need to create a new future that will address the need for supervision and control over Customs business.
   The “as is” permit structure does not; local permits simply don’t matter anymore, and we need to focus on what is needed to replace this outdated structure.
   I have been encouraged by a fellow colleague in the industry to help the individual license holder take a stake in the permit game.
   Regardless of your company’s position on the permit issue, every individual license broker has to think of how any changes will directly affect them. (please send your permit position to permits@ncbfaa.org as they are compiling a collective reply for CBP)
   We must not lose sight of what is at stake here.
   If you are an importer—you should be concerned at a possible reduction of responsible supervision and control over your shipments.
   If you are the government—you should concerned at a possible reduction of responsible supervision and control over import shipments, thereby passing the policing over to you.
   If you are an individual license holder—you should be concerned at the possible elimination of needing your license to qualify a permit.
   Please feel free to share this opinion as baseline support for other individual license holders.
    Of course, it can be reworded for your own need, but try and keep the thrust of the letter’s content to do the most good for all custom brokers.
   The power to create a better future is contained in the present:
   “Create a good future by creating a good present,” said Eckhart Tolle.
Donna M. Mullins

Donna Mullins is President of Mullins International Solutions. Donna can be reached at: 770-626-4802.
donna@mullinsintlsolutions.com

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