NCBFAA responded to the CBP's Notice of Proposed Rulemaking regarding electronic transmission of information prior to cargo being loaded or transported into or out of the United States. The July notice established data filing requirements and time frames for each mode of transportation. The comment period expired August 22nd.
Specifically, NCBFAA said it believed CBP should do a more meaningful analysis of the effect the rules would have on small businesses such as the intermediary (broker/forwarder) community. It cited the implementation of the 24-hour notification rule previously established for ocean shipments.
It also expressed concern that data filed on air, truck, and rail shipments remain confidential. NCBFAA suggested CBP had not considered outbound ocean shipments which are filed using AES and, said NCBFAA, should not be treated as cargo manifest information which is subject to disclosure.
NCBFAA expressed its concern for wording which it said precludes foreign air forwarders not domiciled in the U.S. from filing directly. The need for foreign-based forwarders to file through airlines and other authorized parties will pose a problem for those companies and their U.S. agents and affiliates, said the NCBFAA, and the rules should be broadened. Final rules will be published in the Federal Register.