Written by Susan Kohn Ross

Customs and Border Protection (“CBP”) is in the process of reimaging how it will operate in the future. This effort has been dubbed 21CCF.  At the same time CBP has been developing its recommendations, a national coalition of trade associations has been formed to discuss the very same topic – what should CBP look like in the future? The coalition is identifying topics of interest to the trade community so that when CBP finishes its drafting efforts, the trade community is ready to engage with a clear picture of the desired priorities.

21CCF is the acronym for 21st Century Customs Framework and is the vehicle CBP is using to modernize the laws which govern how the agency operates. Full details about what has been publicly released by CBP can be found here. CBP is working with its own private sector advisory group, called the 21CCF Task Force. The Task Force’s efforts are on-going. The goal is for CBP to develop with private sector support a legislative package for enactment by Congress. Regulatory Practice Group Chair Susan Kohn Ross is both a member of the 21CCF Task Force and active in the private sector coalition.

In the modernization context, one of the points CBP has repeatedly made is that it wants more data earlier in the process and is willing to receive that data from sources other than the importer. CBP states its goal is to know more about a given shipment sooner, so that it can be released more quickly. CBP has also stated it will not rely on data from sources other than the importer, such as the supplier, sub-contractor, etc., unless the importer or its broker validates that data to CBP.

As many of us are involved with multiple trade associations, you may want to give thought to both what you would recommend and the best vehicle through which to make those recommendations. CBP has proposed the trade community provide its suggestions addressing the following questions:

1) What current things are broken and could/should be fixed?
2) What things are okay but could be better?
3) What’s new under the sun (what new rules are needed that did not exist before, such as ecommerce)?
4) Where do we see things going in the future?

What are your thoughts? This is a rare opportunity for input by all interested parties, so make your voice heard!