The National Customs Brokers & Forwarders Association of America (NCBFAA) is urging U.S. Customs and Border Protection (CBP) to exercise caution as it approaches February 28, 2016, when it plans to replace the Automated Customs System (ACS) with the Automated Commercial Environment (ACE).

In addition to accepting manifest, cargo release and entry summary data for all imported goods, ACE will be the single window by which 47 partner government agencies (PGA) involved in the importing and exporting process will receive data about cargo. A number of these PGAs have authority to place holds on cargo, and they will exercise that authority in the cargo release process.

While the organization applauds the revised dates, from November 1 to February 28, noted an open letter to importers and exporters, “NCBFAA remains very concerned about the continued reliance on a new date to shut off the older system. We are reminded of the catastrophe to trade occasioned by Australia’s launch of its own new system in 2005 that was driven by a similar approach.”

The rollout of new technology is always fraught with uncertainty but when international commerce is concerned extra steps must be taken to minimize that uncertainty. The NCBFAA pointed to CBP’s recently released functionality allowing air carriers to file their import manifests with CBP in ACE.

“It did not work properly and created havoc with air shipments, resulting in an inability to move shipments, lost business for importers, and significant additional costs for everyone in the supply chain,” the NCBFAA said.

To avoid such a recurrence on an even larger scale with the switchover to ACE, the NCBFAA suggested that any final implementation date take into consideration a number of criteria. The average time of cargo release in ACE must be equal to or better than the average time of release in ACS. Government exam reasons and results must clearly communicate who is requiring additional action and what actions are required from the trade. All data elements must be established, published, successfully tested and finalized a minimum of 90 days before any piece of functionality is to be put in production. Information collected at the time of cargo release must be for the purpose of establishing the risk of allowing the good to proceed into U.S. commerce. Data requirements must not add costs to the supply chain. CBP and PGA software must be thoroughly tested and pass at an industry-accepted level.

NCBFAA remains committed to a successful ACE system but is concerned that CBP has too few resources available to support the ACE transition. The rollout schedule, NCBFAA contends, is heavily influenced by arbitrary White House deadlines instead of being driven by the completion of software functionality. PGAs are including new data elements and data submission requirements that transfer costs from the PGAs to brokers and importers.

“While we move into an environment where global trade is increasing, a reliable, efficient and predictable process at the point of importation is critical,” the NCBFAA said. “We believe that ACE will answer those needs, and a reasonable adoption of the system will accomplish this.”