US –CBP to permit submission of PGA forms through DIS until ACE mandatory deadlines

On April 22, 2016, U.S. Customs and Border Protection (CBP) issued CSMS#16-000321 (and 16-000320) announcing that the below listed Partnering Government Agencies (PGAs) are now allowing the submission of the forms on the linked list to CBP and the appropriate agencies through the Document Imaging System (DIS) for ACE Cargo Release filers for an interim period from now until the ACE PGA message set and/or DIS becomes mandatory for PGA data.

The following agencies have agreed to allow their forms to be submitted via DIS during the course of their pilots until the ACE mandatory dates:

• Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF)
• Drug Enforcement Administration (DEA)
• Environmental Protection Agency (EPA)
• Fish and Wild Life Service (FWS)
• National Marine Fisheries Service (NMFS)

CBP states that the PGA forms that require approval and/or signature by the PGA must obtain the approval/signature from the PGA prior to submitting the form in DIS. Those forms requiring PGA approval prior to submission in DIS are indicated by an asterisk in the forms list. These forms include the ATF Release & Receipt of Imported Firearms, Ammunition and Implements of War Form (6A) and the EPA Notice of Arrival of Pesticides and Devices Form (EPA 3540-1). Also, the ATF Form 6A no longer needs to be signed by CBP and mailed to ATF if the form is submitted through DIS. In addition, the EPA Form 3540-01 mentioned above does not need to be signed by CBP. Unless deemed necessary, there is no requirement for CBP to print out the submitted forms from DIS.

During this interim period, filers do not have to submit the forms in paper to CBP. Filers need only to upload the PGA forms via DIS in order for CBP to verify the PGA requirements have been met.

Filers participating in PGA pilots may still submit the required data via the PGA message set. This interim DIS policy is merely providing the option for Cargo Release filers to submit the attached set of PGA forms in DIS until the data captured in those forms will be required to be submitted through the PGA message set.

Once all ACE mandatory dates are implemented, all filers will have to conform to the PGA message set and/or DIS requirements set forth by each PGA. For example, the National Highway Safety Traffic Administration (NHTSA) filings are currently mandatory in ACE, and the HS-7 Declaration data must be transmitted with the PGA message set, so the HS-7 does not qualify for submission through DIS.