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COAC Details ‘Grave Concerns’ Over ACE PGA Filing Pilots

COAC Details ‘Grave Concerns’ Over ACE PGA Filing Pilots

Excerpt from International Trade Today  |  November 2, 2015

The CBP Advisory Committee on Commercial Operations has “grave concerns” about the ongoing pilot of Food and Drug Administration filing in the Automated Commercial environment, it said in a memo posted to the CBP website Nov. 2 (here). FDA is “not piloting reality,” instead testing an artificial process where importers must go through multiple steps to pre-validate shipment data, said the memo, which also detailed PGA filing issues related to the other agencies. With the Feb. 28 mandatory date for FDA filing fast approaching, FDA “needs to pilot real data in order to adequately identify issues and test the success of their ACE deployment,” said the COAC.

Currently, FDA is requiring that importers participating in the pilot provide a spreadsheet of shipment data along with each entry filing, which is then checked for any discrepancies against the agency’s internal database, said the memo. Once everything completely matches up, the filer must then transmit through CBP’s artificial certification testing environment, and finally through the regular ACE production environment if no issues arise. The process is “not sustainable” given the amount of time required for all parties involved. Once FDA’s system goes live “in just a couple of months,” there will continue to be mismatches in data, and the COAC is “worried that these continued mismatches will throw everything to human review and bring FDA-regulated imports to a crawl,” it said.

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