The National Marine Fisheries Service should give customs brokers plenty of lead time to adjust to changes to the agency's Certification of Admissibility form as the agency implements revisions to the regulations governing import provisions under the Marine Mammal Protection Act, according to comments from the National Customs Brokers & Forwarders Association of America.
The comments come in response to NMFS's recently announced proposed rule to review the import provisions under the MMPA (see 2607280040).
The NCBFAA said it welcomes plans to automate the COA process, as it would "ensure the continued flow of trade" while meeting MMPA requirements.
"The current COA process introduces clunky manual steps in an otherwise streamlined, automated flow of data, so we are eager to see these changes implemented," NCBFAA President Karen Damon said in an Aug. 21 letter. "We appreciate that NOAA/NMFS is working to avoid duplication of data elements already required by other NMFS programs. This is critical, since we already provide the same data elements multiple times when other NMFS programs apply to the entry. We also appreciate the agency’s efforts to align the COA form with the data elements required in the Message Set, which will facilitate entry of the data in the Automated Commercial Environment (ACE)."
The trade group provided seven recommendations to NMFS, with much of it focused on facilitating the transition to the revised COA form process.
"After the final revisions are published in the Federal Register and the draft [CBP and Trade Automated Interface Requirements (CATAIR)] is finalized, software vendors will then program the new Message Set into brokers’ software. This process can be expected to take 30 to 60 days after the final CATAIR is posted," the letter said. "We request an additional three to four months for brokers to 1) test the software in their own systems and work out any anomalies with the vendor; 2) implement the changes in their own automated workflow; 3) train employees; and 4) communicate with importers on any new items of information."
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