The document discusses a workshop on electronic filing of certificates held by the U.S. Consumer Product Safety Commission (CPSC). It provides an overview of the CPSC's current and proposed rules regarding certificates of compliance for imported consumer products. The CPSC aims to modernize certificate collection by requiring electronic filing of certificates with U.S. Customs and Border Protection at the time of entry. This is intended to streamline the entry process and allow the CPSC to more efficiently review products for safety. The document also outlines the CPSC's risk assessment methodology and collaboration with CBP through data sharing and a pilot risk assessment system.
An overview of the CPSC PGA message set, electronic filing alpha pilot, and certificate registry with walkthrough of example filing and detailed information on proposed timeline
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Slides for morning discussion session of electronic certificate workshop on a *proposed* amendment to the current certification rule, 16 CFR Part 1110. Slides consist of CPSC staff presentation followed by non-CPSC panelist presentations.
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An overview of the CPSC PGA message set, electronic filing alpha pilot, and certificate registry with walkthrough of example filing and detailed information on proposed timeline
How to locate CPSC data on regulatory non-compliance notices, which are also called "letters of advice" (LOAs). The referenced Excel table will be updated frequently with the names of the firm, the foreign manufacturer, and other information. Businesses may integrate this information into their compliance workflows to assist them in sourcing safe & compliant consumer products.
Slides for morning discussion session of electronic certificate workshop on a *proposed* amendment to the current certification rule, 16 CFR Part 1110. Slides consist of CPSC staff presentation followed by non-CPSC panelist presentations.
This panel is especially suited for those attendees who are already familiar with the section 15 reporting obligations and have interacted with Compliance/Field staff on investigations and actual recalls. Includes discussion of priority issues related to being prepared in the event a recall is necessary, working effectively with Field investigators during inspections, how to improve recall effectiveness through the appropriate remedy choice and how to ensure safe adequate disposal of recalled products.
An overview of the CPSC PGA message set, electronic filing alpha pilot, and certificate registry followed by a presentation on the answers to key questions asked at the previous webinar. The COAC working group provided additional feedback and questions during a live Q&A session.
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An overview of the CPSC PGA message set, electronic filing alpha pilot, and certificate registry followed by a presentation on the answers to key questions asked at the previous webinar. The COAC working group provided additional feedback and questions during a live Q&A session.
Overview of third party testing rules for children's products, including initial certification testing, material change testing, and periodic testing if you have continued production. Presentation also addresses optional component part testing. A review of mandatory recordkeeping requirements and undue influence training is also discussed. Pairs with video at http://www.youtube.com/watch?v=cR4RXQjmqC8
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CPSC experts and representatives of a law firm used this presentation to discuss testing and certification issues, component parts testing, and certificates of conformity.
Phthalate determinations as a means for third party testing cost reduction: questions, issues, and comments. CPSC staff presentation followed by panelist presentations.
Staff introduction for CPSC workshop on third party testing cost reduction through possible material determinations. Provides workshop agenda, background, and workshop goals
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CPSC Risk Assesment Model (RAM), CBP Automated Commercial Environment (ACE), & Pilot Programs
1. U.S. Consumer Product Safety
Commission
1
CPSC Staff Workshop on Electronic Filing of
Certificates as Included in Proposed Rule on
Certificates of Compliance
September 18, 2014
This presentation was prepared by CPSC staff, has not been reviewed or approved by,
and may not reflect the views of, the Commission.
2. For those of you in the room, please mute electronics and phones.
For those of you watching on the web, you can email questions for the speakers to:
efiling@cpsc.gov.
The transcript for today’s workshop will be added to the docket at:
www.regulations.gov Docket number: CPSC–2013–0017
The PowerPoint presentations will also be available at:
http://www.slideshare.net/USCPSC
3. John Blachère
This presentation has not been reviewed or approved
by the Commission and may not reflect its views
9/19/2014 3
4. Presentation Acronyms
HTSUS – Harmonized Tariff Schedule specific to the
United States
ITDS – International Trade Data System
CBP – U.S. Customs and Border Protection
9/19/2014 4
5. Certificates – Current
CPSA section 17(a)(2) - requires the
Commission to refuse admission for
regulated products not accompanied by a
certificate
CPSA section 14(a)(2) – requires testing and
certification before importation
CPSA section 14(g)(3) – requires certificates
to accompany the product or shipment of
products, as well as be provided to CPSC
and CBP upon request.
9/19/2014 5
6. Existing 1110 Rule
Paper or electronic certificates (URL typically on the
product, container, or invoice)
Electronic certificates must be created before
importation
Available to CPSC and CBP as soon as the product
or shipment itself is available for inspection.
In practice, Certificates:
Obtained and reviewed at the time of entry through
broker or importer which may take time to present
and may delay release
No ability to assess industry compliance with
requirement
9/19/2014 6
7. Certificates - Proposed
Proposed rule (proposed 16 CFR §1110.13) –
certificates for imported products must be filed
electronically with CBP at the time of filing the CBP
entry or at the time of filing the entry and entry
summary, if both are filed together.
Aligns with Executive Order 13659: “Streamlining the
Export/Import Process for America's Businesses”
Entering required data elements for certificates at the
time of entry would allow the agency to
Electronically review and facilitate release
Prioritize examinations with certificate data at entry
9/19/2014 7
8. Risk Assessment Methodology (RAM)
CPSA Section 17(h)(1) Requires CPSC to:
Establish and maintain a permanent product surveillance
program, in cooperation with other federal agencies, to
carry out the Commission’s responsibilities and to
prevent the entry of unsafe consumer products into the
commerce of the United States.
CPSIA Section 222(a) Requires CPSC to:
Develop a Risk Assessment Methodology (RAM) that
identifies shipments of consumer products that are
(1) intended for import into the United States; and
(2) likely to include consumer products in violation of
Section 17(a) of the CPSA (15 USC 2066(a)) or other
import provisions enforced by the Commission.
9/19/2014 8
9. Risk Assessment Methodology
(RAM)
CPSIA Section 222(b) requires CPSC RAM
development to:
Use CBP’s ITDS insofar as practicable,
Incorporate the RAM into CPSC’s IT
modernization plan, and
Examine how to share information with CBP for
the purpose of identifying risky shipments.
9/19/2014 9
10. Total Risk Management at Import
Monitoring
Shipment activity by product, entity, and port/region
Violation history/risk by product, entity, and port/region
Address risk in product areas and entities at import.
Examples:
Limited complexity: ATVs
High complexity: Toys
9/19/2014 10
11. Risk Assessment Program
Components
Intergovernmental Memoranda of Understanding
and agreements
Collocated personnel with CBP
Integration with CBP data systems - pilot system
Other improvement projects
Product coding
Internal case and process monitoring
9/19/2014 11
12. Risk Assessment Program
Components
Intergovernmental Memoranda of Understanding
and agreements
Collocated personnel with CBP
Integration with CBP data systems - pilot system
Other improvement projects
Product coding
Internal case and process monitoring
1
9/19/2014 12
13. Risk Assessment Program
Components
Intergovernmental Memoranda of Understanding
and agreements
Collocated personnel with CBP
Integration with CBP data systems - pilot system
Other improvement projects
Product coding
Internal case and process monitoring
2
9/19/2014 13
14. Collocated Staff
Works cooperatively at ports to target and screen
shipments
Chemical analysis – XRF and FT-IR
Mechanical analysis – Use/abuse and physical
assessment
Document verification – Certification and tracking
labels
9/19/2014 14
15. Risk Assessment Program
Components
Intergovernmental Memoranda of Understanding
and agreements
Collocated personnel with CBP
Integration with CBP data systems - pilot system
Other improvement projects
Product coding
Internal case and process monitoring
3
9/19/2014 15
16. Pilot System (ITDS/RAM)
Integrates available risk information to model and
support Commission enforcement strategy
involving product hazards at importation
Potential sources of risk data include:
Shipment (CBP)
Case history (CPSC & CBP)
Examination history (CPSC)
Injury and death (CPSC)
Commercial information (Third Party)
9/19/2014
14
17. Pilot System Functions
Statistical modeling to assist in the prioritization
of projects and operations
Risk-based standard reporting for product
managers to know importation patterns
Graphical User Interface to manage screening
and exams at ports of entry
Systematic assessment methodology to review
and prioritize all shipments of potential
interest to CPSC
9/19/2014
15
23. Risk Assessment Program
Components
Intergovernmental Memoranda of Understanding
and agreements
Collocated personnel with CBP
Integration with CBP data systems - pilot system
Other improvement projects
Product coding
Internal case and process monitoring
4
9/19/2014 23
24. HTSUS Reclassification
Work with the U.S. International Trade Commission on
the reclassification of some product areas to support
regulation enforcement and defect identification
Completed once for the January 1, 2011 mapping
Toys
ATVs
Children’s Durable Products
Drywall
Second set under review
9/19/2014 24
25. Modernizing Certificate Collection
Will:
Reduce the shipments reviewed that are compliant
or out of scope
Reduce the time spent per shipment to verify
compliance with our laws
Improve the rate of discovery of hazardous/violative
products per staff month
Provide a single, reliable store of certificate data
9/19/2014 25
26. John Blachère
This presentation has not been reviewed or approved
by the Commission and may not reflect its views
9/19/2014 26
27. Single Window and
Automated Commercial Environment
(ACE)
Brenda Smith
ACE Business Office
CPSC Workshop on Electronic Filing of Certificates at Entry
September 18, 2014
29. Single Window Authorization and Support
Executive Order signed February 19, 2014 – Streamlining the
Export / Import Process for America’s Businesses
Directs 47 U.S. Federal agencies with a role in trade to be ready to
participate in the electronic “Single Window” by December 2016
Expands scope of the Border Interagency Executive Council (BIEC)
to all agencies with a border interest
ITDS Board of Directors provides executive leadership and
direction, and works with PGAs on automation
ACE Executive Steering Committee (DHS and CBP executives)
provides oversight and guidance to the ACE Program to ensure
successful development and operation
29
30. IT Foundation for the Single Window
ACE will automate trade processing and data collection for 47 federal agencies
Enhances agency enforcement missions through
trade targeting and risk segmentation
Increased USDA food seizures 30-fold
Automated processes saving CBP $46M/year
Reduces U.S. supply chain transaction costs
Streamlines interagency processing through
collaboration and less paperwork
Strengthens the global supply chain to protect U.S.
interests and enhance prosperity
Supports U.S. manufacturing growth by facilitating
exports
National Export Initiative
Single Window
Security and Safety
One U.S. Government at the
Border
U.S. Economic
Competitiveness
Global Supply Chain Strategy
Automated Commercial Environment
33% faster truck processing
Up to 76% duties/fees paid interest free via ACE
Nine agencies receiving automated data via ACE
Pre-arrival data linked and available in ACE
Participating ocean carriers saving $900K/year in
reduced courier costs
30
31. Implementing the Single Window
Three enablers provide the means for Partner Government
Agencies (PGAs) to participate in ITDS/ACE
Partner Government Agency (PGA) Message Set - Establishes
a single, harmonized set of information to be collected
electronically from international traders by CBP on behalf of PGAs
Interoperability Web Services - Provides a system-to-system
pipeline for data transfer between CBP and PGAs
Document Image System (DIS) - Allows trade members to
supply images of needed documents electronically during the
cargo import and export processes
The ACE portal provides PGAs with a graphical user interface (GUI) to
view the data in ACE, search on that data and run reports. The ACE portal
is a consistent interface across PGAs that differs only by their particular
information and processing needs.
31
32. PGA Integration Status
4 9 9
32
2
2
10
11
6
9
30
25
20
15
10
5
0
PGA Message Set Document Image System
(DIS)
Interoperability Web
Service (IWS)
Developed In Progress Remaining
PGAs
• CPSC is among the nine agencies using IWS capabilities
33. PGA Message Set Processing Benefits
Today, PGA data is submitted manually via paper forms, requiring human
intervention and manual correlation with transactions
PGA Message Set extends existing CATAIR message set to allow
submission of PGA data electronically to CBP along with entry and entry
summary filings
The Single Window will streamline transmission, processing and distribution
of PGA data, yielding significant cost savings and efficiency:
Trade and multiple government agencies will no longer exchange information via
multitude channels during the cargo release process
Data will be available to agencies more quickly, allowing for better identification
of dangerous or prohibited shipments
Automated PGA interactions reduce paper and enable near-real time decision
making by Government authorities
Single Window makes it easier for industry to comply with government
regulations and reduces costs for Government and industry
33
34. PGA Onboarding Process
47 PGAs to be on-boarded in three phases, beginning with PGAs with
Cargo Release responsibilities
Phase I – Initial capabilities deployed to 10 agencies by April 30, 2014
Phase II – Advanced capabilities deployed to 13 agencies by July 4, 2015
Phase III – Advanced capabilities deployed to remaining agencies by
July 1, 2016
34
35. CPSC Connectivity Status
IWS enabled October 2011
CPSC receiving production entry and entry summary data
directly from CBP
CPSC upgraded to advanced Event Exchange capability in IWS
on September 10, 2014
CBP and CPSC are engaged in on-going discussions to plan
for exchange of forms via DIS to supplement the admissibility
review process
Planning to be DIS capable with July 4, 2015 ACE deployment
35
36. Mandatory Dates for Transition to ACE
Date Mandatory Requirement Time Remaining
May 1, 2015 Mandatory use of ACE for electronic
import and export manifest filings
8 months
November 1, 2015 Mandatory use of ACE for electronic
Cargo Release and related Entry
Summary filings
14 months
October 1, 2016 Mandatory use of ACE for all
remaining portions of the CBP cargo
process
25 months
36
40. Food Safety and Inspection Service
Food Safety and Inspection Service
Pilot for PGA Message Set
Bob Berczik
International Relations and Strategic Planning Staff
Office of Public Policy and Program Development
Food Safety and Inspection Service, USDA
40
41. Food Safety and Inspection Service:
Mission in Action
We are the public health
agency in the USDA
responsible for ensuring
that meat, poultry, and
processed egg products
are safe, wholesome, and
accurately labeled.
• Federal Meat Inspection Act (FMIA), 1906
• Agricultural Marketing Act (AMA), 1946
• Poultry Products Inspection Act (PPIA), 1957
•Humane Methods of Slaughter Act (HMSA), 1958
• Egg Products Inspection Act (EPIA), 1970
Our Authority
Through a series of Acts, Congress
empowers FSIS to inspect all meat,
poultry, and processed egg products
in interstate commerce.
41
42. Public Health Information System (PHIS)
o Designed to collect, consolidate, and analyze data derived from both domestic
inspection and foreign country inspection systems
o Centralized computer database that generates random import inspection tasks and
stores inspection results, based on:
• Exporting country, process category, species, performance
o Interconnected with US Customs and Border Protection’s (CBP) Automated
Commercial Environment (ACE)
o Pre-populates shipment data received from industry, enhancing controls and reducing
fraud
• PHIS connection to ACE
• Partner Government Agency (PGA) Message Set
PGA Message Set Pilot underway with two brokers making entries at three POEs with
nationwide implementation to follow
o GOAL: to streamline the Customs entry process and transition away from paper –
based application process for FSIS import inspection
42
43. PHIS
o Enables interface with U.S. Customs and Border
Protection’s Automated Commercial Environment (ACE)
system
• Business-to-government exchange of shipment data
• Provides FSIS Advance Notice when Customs entry filed
• Replaces paper application for inspection (Form 9540-1)
Uses existing data collected by CBP
Incorporates FSIS specific data into the CBP standard data set
(UN/CEFACT and WCO compliant)
43
44. o Importers are required to apply for
FSIS import inspection for all
entries of meat, poultry, and egg
products
o An Entry or Entry Summary
Certified for cargo release in ACE,
combined with the PGA Message
Set, will eliminate the need for
paper applications
• An electronic FSIS Form
9540-1 will expedite the
clearance process on
regulated shipments
FSIS Import Application (FSIS Form 9540-1)
44
45. o Electronic import application
in PHIS retrieves data from
ACE
• PGA Message Set data completes
the data fields missing from the
FSIS import application
o For example
• Broker information provides local
broker first name*, last name*,
phone number,* email address*
or fax number
o *Data fields are required in
PHIS import application
• PHIS utilizes information to
exchange electronic messages
between FSIS and Trade
Current Partial Data Feed
45
46. Data Complete with Message Set
PG19 CB
PG21 LOCAL BROKER CONTACT INFORMATION – FIRST NAME AND LAST NAME,
LOCAL PHONE NUMBER, AND E MAIL ADDRESS – MARTHA STEWART 313-666-
7777 JAS2@hotmail.com
PG21 LOCAL BROKER FAX NUMBER IS 313-666-7771
46
47. FSIS Data Grouping
The PGA Message Set accommodates the following “many-to-one”
data relationships:
o Many inspection certificates to one entry
• The PG 50 and 51 start and end the groupings
• Multiple PG 14 (inspection certificates) may relate to the PG
13 (the foreign government that issued the certificate)
o Many lots within one inspection certificate
• The PG 50 and 51 start and end the groupings
• Multiple data lines providing specific lot information are
related to the PG 14 (inspection certificate)
47
48. Foreign Inspection Certificates
o FSIS requires all imported meat, poultry and egg products to be properly
certified by the competent authority in the exporting foreign country
o The electronic import application in PHIS uses a combination of
information supplied in part from Trade and from the foreign inspection
certificate
• Currently PHIS receives official certification data electronically from Australia,
New Zealand, and the Netherlands*
• For shipments certified electronically, when importers/brokers identify the
inspection certificate number through the PGA Message Set, FSIS PHIS will
populate the import application based on the eCert data
o Filers making entries from countries that do not certify shipments
electronically must provide additional PGA Message Set data identifying
product attributes
*Note: FSIS will develop the capability to exchange official certification data
electronically with other foreign governments
48
49. FSIS Message Set Pilot
o The FSIS PGA Message Set Pilot began on April 27, 2014
o FSIS pilot has two Customs brokers actively participating:
• A.N. Deringer, Broker Filer, Code 551
• Barthco International Inc. dba OHL International, Broker Filer Code
OHL
• Customs brokers participating in the pilot have the option to file
entries with or without the complete message set data elements
o Pilot entries are at three ports of entry:
• Champlain, NY, Port Code 0712
• Philadelphia, PA, Port Code 1101
• Houston, TX Port, Code 5301
49
50. FSIS Message Set Pilot
o From April 27, 2014 through September 4, 2014, the two participating
brokers in the FSIS pilot have submitted a combined 109 entries through
ACE utilizing the PGA message set representing 4.5 million pounds of
product under FSIS jurisdiction
o Entries filed are for product from Canada, Australia and New Zealand
o Product from Australia and New Zealand are interfacing with government-to-government
inspection certificate data exchange (eCert)
50
Message Set Entries by Import Country of
Origin
Canada (A.N.Derringer)
Australia (OHL combined with
eCert)
New Zealand (OHL combined
with eCert)
51. FSIS Message Set Pilot
o 87% of the pilot entries had no identified issues
o 13% of the pilot entries to date had identified issues
o Types of issues encountered:
o Data mapping both internal to FSIS and external to filer software use
o HTS conflict (1 entry)
Note: No identified issues delayed shipment movement or reinspection of
product by FSIS. No data transfer issues from ACE to FSIS have been
identified.
51
52. FSIS Message Set Pilot (software validations)
o Automation of eCert pre-population of the application based on the
PG14 record from the filer
• 42 entries submitted validated the success of eCert filings from
Australia and New Zealand systems.
o Multiple inspection certificates (PG14) identified on a single entry
• 6 entries submitted with multiple certificate numbers and PHIS created
separate applications based on the PG14 records as expected
o Increase shipment monitoring capabilities to prevent Failure to
Present (FTP)
• PG 30 record facilitates FSIS monitoring
o Elimination of FSIS import inspectors to manually enter application
data increases efficiency of reinspection process
52
53. References
o Data Samples and Guidelines for Using the PGA Message Set for Electronic
Completion of the U.S. Department of Agriculture (USDA), Food Safety
Inspection Service (FSIS) Application for Import Inspection (FSIS Form 9540-1)
http://www.fsis.usda.gov/wps/wcm/connect/98c45f3c-8a5b-47d7-9907-
2fdc7352547f/Data_Samples_Guidelines_PGA_Message_Set.pdf?MOD=
AJPERES&CACHEID=44196b9d-4fc1-45e0-a1de-eb3701385366
o Public Health Information System (PHIS) – Import Component
http://www.fsis.usda.gov/wps/portal/fsis/topics/international-affairs/importing-products/
phis-import-component/CT_Index1
53
54. FSIS Contacts
Bob Berczik
202-690-4163
Robert.Berczik@fsis.usda.gov
Mary Stanley
202-720-0287
Mary.Stanley@fsis.usda.gov
54
55. EPA ACE Pilots:
Looking for Volunteers
Consumer Product Safety Commission
Workshop on Electronic Filing
Bethesda, MD
September 18, 2014
56. Topics
• EPA-regulated commodities
• What we are doing
• What Trade can expect
• Pilot programs
• Trade Participation, Getting Started
• Sample Message Set
• Summary
• Questions?
56
57. 57
EPA-Regulated Commodities
Under environmental statutes
administered by EPA, six
programs have import safety
responsibility.
Ozone Depleting Substances (CAA)
Vehicles and Engines (CAA)
Fuels (CAA)
Toxic Substances (TSCA)
Pesticides (FIFRA)
Hazardous Waste (RCRA)
• Statutory requirements are built
on risks to human health and the
environment.
• Admissibility of EPA-regulated
commodities are based on
compliance to statutory
requirements (reporting).
58. ODSTS
Verify
PRISM
58
What We Are Doing:
eFiling, Automated Processing
Internet
ODS
Engines
Pesticides
Hazardous
Waste
WIETS
Importers, Brokers,
& Carriers
Central Data
Exchange (CDX)
CBP & EPA
Import Data
Customs
and
Border
Protection
ACE Data
Warehouse ACE/ITDS Single
Window
ABI Interface
EDI
ACE’s ESB
EPA’s
Network Node
XML
EPA
Staff
Streamline, improve reporting/processing of legal imports/exports
• Paper to electronic filing (Entry, Entry Summary Certified for
Release, Simplified Entry/Cargo Release) –Partner Government
Agency (PGA) Message Set, Automated Broker Interface (ABI)
• Validations to automate reviews for many EPA-regulated
commodities
• Electronic status messaging – ABI messages (including errors
and clearance)
• Updates, corrections – before arrival at, exit from ports
Goal: Early indication reporting requirements are met
BEFORE cargo is loaded on a plane, truck, train, or
ocean vessel.
59. 59
What Trade Can Expect:
• Shortened review/processing time from current paper
filings (in some cases from days/weeks to minutes/seconds)
• Standardized filing process for EPA-regulated commodities
at all Ports nationwide
• Eliminate duplicate reporting to EPA, CBP
• Eliminate courier fees
• Error responses for invalid filings to provide specific
information (data element level)
• Ability to update and correct PGA Message Set filings
(future)
60. 60
Pilot Programs
• Current pilots in production (April 30, 2014)
– Ozone Depleting Substances
– Vehicle and Engine Declarations
Starting in ports of Long Beach and Newark
• Pilots planned for fall/winter 2014
– Notice of Arrival for pesticide imports
Starting in ports of Chicago, Port Huron, Newark
– Hazardous Waste Exports (Spent Lead Acid Batteries)
Starting in ports of Hildago, Laredo
• Get started now
– PGA Message set samples, get going with software developers
61. Trade Participation
• What you will do
– Create message sets
– Submit Test filings to the Certification Environment in ACE
– Receive, respond to Customs And Border protection (CBP)
notifications if needed
– File in Production
• What you need to file (boiled down):
– Ozone Depleting Substances (ODS): approved importer of record,
quantity
– Vehicle/Engine Declaration: Data from forms 3520-1 and 21;
certification number
– Pesticides Notice of Arrival: Data from form 3540-1; registration,
producer establishment number
– Hazardous Waste Exports: Consent number 61
62. Getting Started
62
• Are you an ACE Filer? Talk to your CBP Client Rep.
• Are you filing these commodities at these ports?
• Confirm participation.
– Current Pilots - Contact me and your Client Rep to get started.
– Planned Pesticide Pilot - Respond to CBP-issued Federal Register
Notice (expected Fall 2014), contact me.
– Planned Hazardous Waste Export Pilot - contact me.
• Work with EPA and your software developers. Begin
identifying PGA Message Set adjustments to your
software (EPA will work with you on examples).
63. Sample PGA Message Set
1 2 3 4 5 6 7 8 9
10
1 2 3 4 5 6 7 8 9
20
1 2 3 4 5 6 7 8 9
30
1 2 3 4 5 6 7 8 9
40
1 2 3 4 5 6 7 8 9
50
1 2 3 4 5 6 7 8 9
60
1 2 3 4 5 6 7 8 9
70
1 2 3 4 5 6 7 8 9
80
O I O F F M O S Q U I T O R E P E L L E N T
P G 0 1 0 0 1 E P A P S 1 Y
P G 0 2 P
P G 0 7 O F F M O S Q U I T O R E P E L L E N T
P G 1 4 2 E P 8 6 9 3 4 0 - 8
P G 1 9 E P N 0 1 2 3 4 5 C H N 0 0 2
P G 1 9 C B S U P E R C U S T O M S B R O K E R A G E C O M P A N Y 5 0 0 E A S T 1 7 T H S T R E E T
P G 2 0 1 0 0 N E W Y O R K N Y U S 1 0 0 1 2
P G 2 1 C B J O H N S M I T H 2 0 2 2 3 4 5 6 7 8 J O H N . S M I T H @S U P E R B R O K E R A G E . C O M
P G 1 9 I M B U G S P R A Y I M P O R T C O M P A N Y 3 4 5 N E WB E R R Y S T R E E T
P G 2 0 2 0 3 B O S T O N M A U S 0 2 1 0 5
P G 2 1 I M J A N E S M I T H 6 1 7 2 3 4 5 6 7 8 J A N E . S M I T H @B U G S P R A Y I M P O R T . C O M
P G 5 5 N P C I
P G 1 9 O V M A R I T I M E I N D U S T R I A L S H I P P E R S 6 0 0 P O R T R D
P G 2 0 N E WA R K N J U S 2 0 0 3 4
P G 2 1 O V J A Y S M I T H 4 1 0 1 1 2 3 4 5 6 J A Y . S M I T H @M A R I T I M E S H I P P E R S . C O M
P G 1 9 D E Q S U P E R I O R S H I P P I N G C O M P A N Y 4 3 2 P O R T B O U L E V A R D
P G 2 0 L A P U - L A P U C I T Y P H 3 2 3 4 0 2 4 8 6
P G 2 1 D E Q J O H N R E Y E S 6 3 3 2 4 1 1 5 8 0 0 J O H N . R E Y E S @S U P E R I O R S H I P P I N G . P H
P G 1 9 L G F A M O U S S T O R A G E A N D WA R E H O U S E 1 2 3 4 5 J E R S E Y A V E
P G 2 0 N E WA R K N J U S 0 7 3 1 0
P G 2 1 L G M A R K 6 6 3 2 4 5 7 7 8 3 3 M A R K . J I M@T I M E . C O M
P G 2 2 9 4 4 C I E P 3 Y 0 2 1 1 2 0 1 4
P G 2 6 2 0 0 0 0 0 0 0 0 1 0 0 0 O Z
P G 2 6 1 0 0 0 0 0 0 1 0 0 0 0 0 B O
P G 2 9 K G 0 0 0 0 0 0 0 2 8 4 5 3
P G 0 2 C C A S 9 4 2 7 1 - 0 3 - 1
P G 0 4 Y D E E T 0 1 5 3 7 5 7
P G 0 2 C C A S 5 2 3 0 4 - 3 6 - 6
P G 0 4 Y I R 3 5 3 5 0 3 5 0 0 0 0
P G 0 2 C C A S 1 1 9 5 1 5 - 3 8 - 7
P G 0 4 Y P I C A R I D I N 0 0 5 5 0 0 0
P G 0 2 C P C 0 0 6 4 9 1
P G 0 4 Y B T M O C R Y 1 F 0 0 2 1 0 0 0
8/28/2012 U.S. Environmental Protection Agency 63
64. Summary
• EPA and CBP are testing in pilots
– Moving to eFiling, automated processing
• Need Trade volunteers to test
– eReporting, early filing, messaging
– Look for Federal Register Notice for pesticides pilot
– Contact your Client Rep and me if you are interested
64
65. 65
For More Information
Roy Chaudet
Office of Information Collection
Office of Environmental Information
U.S. Environmental Protection Agency
202-566-1703
chaudet.roy@epa.gov
69. 13th Term COAC 1 US
Government @ TB November 2013 Public Meeting
Recommendations
Unified Filing of Entry Information
Entry and PGA data sent well in advance
of cargo arrival
CBP and PGA review data in advance of
cargo arrival, screening for data
accuracy, importer & product
compliance etc.
Clear PGA responses to filer at the line
level
Sound Risk Assessment methodologies
employed (prefer to use data not
69
70. 13th Term COAC 1 US
Government @ TB Trusted Trader Program
Expedited clearance for known importers
Leverage CBP and Trade’s investment in C-TPAT,
ISA or FS
Single Window Efficiencies
Collect only the data required and utilize
data collected for other purposes for the
PGA data whenever possible
Consider alternative method of identifying
importers/exporters/foreign facilities – DUNS
number?
Risk Assessment Methodology system must be
robust, recognizing compliant importers,
70
71. 13th Term COAC 1 US
Government @ TB Single Window Challenges
Ability to timely obtain the right data from
the actual importer well in advance of
cargo arrival
Key entry errors – they will occur! The more
data required, (especially free form, not
table driven) the greater the chance for
errors
Management of data across all PGA
message sets will be a challenge to the entry
filer and the importer. Data creep is a major
concern for the trade community
When data anomalies occur, immediate
feedback to the filer must be given in form of
71
72. Business Needs & Realities
The Global Supply Chain is constantly evolving
– legitimate trade should be managed as
efficiently as possible
Non-resident Importers of Record are
becoming more common.
Business to Consumer (B2C) shipments are
increasing
Trade moves 24/7 – need the PGAs to make
admissibility decisions well in advance of
arrival to keep goods flowing.
Set High vs Medium vs Low Risk Priorities and
perform post entry audits.
Staged implementation (similar to APHIS
72
73. Keys to Success
Vigorous Trade Participation in ACE
The more you test, the more you learn about
the system, the process and the data
requirements, and the more efficient the
trade will become in managing the data.
Participation in PGA Pilots by Importers and
Brokers who will be affected by the PGA
message set for that Agency is critical to the
success of the PGA Pilot.
Data Quality Issues can be addressed
Mutual Understanding of the Data
Requirements and Commercial Availability of
the Data can be achieved
The Pilot is an important exercise to ensure
73
74. Thank You
One U.S. “Efficient” Government at the Border
Is our GOAL!
74