Trade Reconciliation Webinar Questions and Answers
Yes, the presentation will be posted to CBP.gov.
Supporting documentation should be uploaded upon request from CBP for all issues. Here is a list of documents that may be requested but are not limited to:
- CBP Form 247 (Cost Submission)
- Detailed header and line-level spreadsheets
- Cost analysis spreadsheets
- Commercial Invoice
- Packing list
- Bill of lading
- Purchase orders
- Contracts
- Manufacturer’s affidavit
- Inventory records
- Documents supporting apportionment of assists
- Free Trade Agreement (FTA) certificate of origin
85 FR 39579 states Free Trade Agreements (FTA) reconciliation entries must be filed within 12 months of the earliest import date and the FTA flag expires after 12 months.
After further review, this answer has been modified from the webinar. Yes, freight Deductions can be reconciled. This information will be updated in the Reconciliation Guidance.
- How should importer handle this recon filing?
An importer should request an extension of liquidation or file a no change reconciliation to avoid liquidated damages.
An importer should request an extension of liquidation or file a no change reconciliation to avoid liquidated damages.
There are currently no regulations for reconciliation. Reconciliation operates under the National Customs Automation Program Prototype (NCAP/P), which was announced in the Federal Register (63 FR 6257) and which provides guidance published by CBP on reconciliation entries. CBP is working to codify the test into regulations in the near future.
The importer should request an extension of liquidation or file a no change reconciliation to avoid liquidated damages.
The filer receives reject notification via the Automated Broker Interface (ABI) depending on the software vendor used. The filer/importer has the option to use ACE Report number ES-004 to monitor rejections through ABI and ACE Portal access.
The CATAIR is normally updated when new development is deployed; however, if clarification is needed in the CATAIR we suggest reaching out to your Client Representative for assistance.
No, only flagged issues can be reconciled. If COO or non-reconcilable issues are discovered after the PSC timeframe, then a Protest or a Prior Disclosure is the appropriate path forward.
In this situation, the Protest will be reliquidated, subsequently the original amounts will be incorrect. If this occurs, Center personnel will review and reject it back to the filer.
Entries that have no changes but are flagged for recon still need to be submitted as a "no change" on a recon entry. No change entries would go on a separate recon entry.
- against a recon entry but the recon entry is merely transmitted data consisting of a header record and line data. If specific underlying entry docs are requested trade would need a list of which entries as there may be hundreds of underlying entries associated to that one reconciliation.
Center personnel should identify the specific underlying entry summaries that information is being requested on the CBP Form 28. If this not occurring, please reach out to the processing Center for clarification and assistance.
This is a technical issue. Please contact ace.reports@cbp.dhs.gov for assistance.
All requests for extension of liquidation should be routed to the processing Center email box.
- reconciliation? What is the process or the regulation to guide an importer in correctly stopping reconciliation filing?
Filing for reconciliation is voluntary. The importer may stop flagging at any time.
An extension extends the liquidation, to allow additional time (1 year) for an entry to liquidate. Entries are extended in one-year intervals. The maximum number of extensions on an entry is three. Once processed by CBP, liquidation extensions are posted on the Official Notice of Extension, Suspension and Liquidation bulletin. An extension can be requested by the trade (19 CFR 159.12), or it can be extended on behalf of CBP. Liquidation of a Reconciliation entry may be extended for value, 9802, or classification. Extensions will not be granted for Reconciliation entries flagged for FTA beyond the one year from the date of importation.
Yes, reconciliation would be recommended for transactional value updates.
Bond updates can be tracked via Importer's Bond Query. Prior to filing a recon entry, please check your internal system setting for the importer to ensure that there was no bond change.
Reconciliation is an entry that is filed after the importation of goods into the United States and does not have an impact on the timing and efficiency of goods entering the United States.
This issue occurs when the filer is not allowed to change the recon flag. Currently, there is no intent to change the functionality.
This is a reports technical issue. Please contact ACE Reports at ace.reports@cbp.dhs.gov for assistance.
H231836, dated June 19, 2014, (HQ H293638 (“Honda”) and H031244 (“USPC”), as well as H264394 (Lockheed Martin)). This seems to be inconsistent with CBP’s statement that ACE reconciliation program is CBP’s only accepted method of post-entry adjusting import values. These rulings seem inconsistent with CBP statements regarding reconciliation. Can you comment on whether importers should apportionment of assist costs to an entry in the month or period following the incurrence of such costs or payments, or use recon to identify the appropriate entry or entries to apportion the increase in value?
Value changes can be made via Post Summary Correction and Protest and/or through Reconciliation.
The importer can correct the non-flagged issue by filing a Post Summary Correction or Protest. Please be mindful of the applicable filing timeframes for both.
I am able to successfully run ES-501, ES-504 etc. only trouble with ES-506 and ES-507.
This is a reports technical issue. Please contact ACE Reports at ace.reports@cbp.dhs.gov for assistance.
This is a reports technical issue. Please contact for specific questions regarding ACE Reports at ace.reports@cbp.dhs.gov.
Please contact the Post Release Branch within the Entry Summary Accounts and Revenue Division within the Trade Transformation Office at ESAR@cbp.dhs.gov.
In the situation described, ACE is performing as designed. The solution is a manual process and requires a request to be made to the processing Center to remove the flags.
If the importer requests a cancellation of a flagged entry summary and there is not a replacement entry summary, the importer is not obligated to reconcile the flagged issue(s) if the request to cancel is approved by CBP nor does the flag have to be removed prior to cancellation. If there is a replacement entry summary, then the replacement entry summary should also be flagged for the same recon issue(s). The cancellation would not delete flags on the underlying entries. It is the importers responsibility to request and provide supporting information for the cancellation. If the flagged entry summaries are past the Reconciliation entry due date, they must provide a replacement Reconciliation entry number on the cancellation request and the replacement entry summary number.
This is a reports technical issue. Please contact ACE Reports at ace.reports@cbp.dhs.gov for assistance.
A request to retroactively flag an issue type must be submitted to the Center. Approval for retroactive flagging is done on a case-by-case basis.
There are number of factors that determine the amount of time it will take for a value recon to be liquidated. At this time, CBP is unable to provide an average timeframe for this inquiry.
Only the flagged issue can be reconciled. Clerical errors do not align with indeterminable elements of value at the time of entry summary, therefore clerical errors should not be presented as such for reconciliation. If there is a clerical error of value on an entry summary, a Post Summary Correction should be submitted.
ACE Reports can only pull in information that is entered in the underlying application, such as the Entry Summary application. If an indicator is changed in the application, then it will be picked up in the Entry Summary data universe that night and that data will be displayed in ACE Reports the next day.
A request to retroactively flag an issue type can still be done however the request must be submitted to the Center. Approval for retroactive flagging is done on a case-by-case basis. Further information regarding Retroactive Flagging is available on the Recon External Guidance Page 15 at CBP.gov.
A reconciliation entry may be extended for liquidation for one year and can be requested an additional 2 times for a total of 3 years extended.
CBP would consider this a trade best practice to file reconciliation entries with PSCs and/or protests separate from entries that are not affected due to the possibility of original amounts not matching after the PSC or Protest has been liquidated or re-liquidated. This practice is not a CBP requirement.
Yes, the electronic size limit is 5 MB if you use DIS via email, however you can send multiple emails. If you use DIS via MQ you can send 100 MB on one transmission.
If you have missing data or have a technical issue with ACE Reports, please contact ace.reports@cbp.dhs.gov for assistance.
Please contact ACE Reports at ace.reports@cbp.gov for assistance.
No, the only time the filer needs to submit original amounts is when entries are double flagged. If the entries are not double flagged, the filer does not need to submit the original amounts. If original amounts are submitted, they are not validated or used in processing the reconciliation entry.
Yes, that is correct, the ES-504 Report will give the original amounts ACE currently has on the underlying entries.
Please contact the Center and they can help facilitate the payment issue at the port.
No, you do not need to notify CBP ahead of time. The classification issue must be flagged on the underlying entry.
ACE does not update the FTA data on the underlying entry summaries specifically. The data is captured in the FTA Recon itself for the changes being made to the underlying entries.
The filer should request the Center place the recon entry in reject status
- How long after filing a no change does the importer have to correct this initial filing?
- The filer has until prior to liquidation to correct the initial filing.
- What happens if CBP liquidates a no change recon filing and then a pending classification issue is ultimately resolved.
- The filer may submit a Protest, protesting the liquidation of the classification only.
- to request a refund and pay the duties on the new recon?
The duties taxes and fees will not be transferred to the new Recon entry. CBP will reject the entry back to the importer to remove the late files. When the importer retransmits with the correct duty taxes and fees CBP will issue a refund. The importer will create a new reconciliation entry that only contains the late files and will pay duty taxes and fees if applicable.
Interest Calculations can be found on CBP.gov at Interest Calculation | U.S. Customs and Border Protection
It is not a requirement however the more data that is provided is helpful to CBP.
Per FRNs and CBP policy, additional duty payments must be made via check.
If any underlying entry is double flagged, will require the new 56, 57, & 58 records to be transmitted. The totals are to be reported for all the affected underlying entries whether or not some are not double flagged. If the filer includes even one non-double flagged entry, all the totals are to be reported and are required.
CBP will not be able to take the Value and Duties from the FTA recon Line-Item Transmitted Data and report the Reconciled amounts as Originals to the OTHER because it is reported in an aggregate format. This is what CBP is requiring the filer/importer to report to CBP.