U.S. Customs & Border Prot., Electronic Invoice Program(EIP)/Remote Location Filing (RLF) Handbook (External) Version (2016)
Office of International Trade
Trade Policy and Programs Division
May 2013
U.S. Customs and
Border Protection
| 1.0 | EIP and RLF Program Participation | 2 |
|---|---|---|
| Participating in EIP | ||
| Participating in RLF | ||
| 2.0 | Electronic Entry Program Fundamentals | 3 |
| Program Limitations | ||
| Program Compliance | ||
| Cargo Systems Messaging Service (CSMS) | ||
| RLF and the Automated Commercial Environment (ACE) | 4 | |
| Invoice Messages | ||
| CBP Rulings and Invoice-by-Request | 5 | |
| Invoice Required | ||
| 3.0 | Automated Invoice Interface (AII) Module | 7 |
| 4.0 | Cargo Processing | 14 |
| Examination Request | ||
| “Hybrid” Processing for Other Government Agency (OGA) Requirements | ||
| Designated Exam Site (DES) | 15 | |
| 5.0 | Entry Summary Processing | 17 |
| Payment and Statement Processing | ||
| Ineligible EIP/RLF Entries | 18 | |
| Post Entry Amendments (PEAs), Post Summary Corrections (PSC) and Protests | ||
| Anti-Dumping/Countervailing Duty (Entry Type 03) Processing | 19 | |
| Filing Timeframes | ||
| Census Warnings | 20 | |
| Filing Additional Information | ||
| 6.0 | Enforcement Actions | 21 |
| Introduction | ||
| Liquidated Damages | ||
| Penalties | ||
| Broker Penalties (19 U.S.C. § 1641) | 22 | |
| Non Egregious Violations | ||
| Fraud, Gross Negligence, and Negligence Penalties | 23 | |
| Recordkeeping Penalties (19 U.S.C. § 1509) |
APPENDICES
A. Frequently Asked Questions (FAQs)
24
B. Administrative Messages (CSMS) and Other References
CBP Administrative Messages
CBP Regulations
Federal Register Notices
List of CBP Ports of Entry and Contact Information
C. Definitions
D. EIP/RLF Harmonized Operational Approval Test Package
Electronic Invoice Program (EIP) and Remote Location Filing (RLF) are two electronic entry programs that CBP offers. EIP requires that the trade submit electronic data in place of paper requirements for entry and/or entry summary filing. RLF builds on EIP and allows participants to file an electronic entry package for certain entry types from a location other than the port of arrival or the examination location. EIP and RLF entries and entry summaries are subject to examination or review like any other filing, and they go through the same targeting process. To avoid confusion between different types of CBP paperless programs, filings with electronic invoices will be referred to as “electronic” entries or entry summaries.
The RLF program was authorized by Congress in 1993 with the enactment of the Customs Modernization Act, codified at 19 U.S.C. § 1414. On December 30, 2009, CBP published Federal Register (74 Fed. Reg. 69015), which sets forth the regulations for RLF under 19 C.F.R. § 143, Subpart E.
This handbook reflects national policy and procedures for the EIP/RLF Program. It is annotated with appropriate references to applicable laws, rules, and regulations. The references may be cited to the public and trade community to ensure understanding and compliance with the procedures outlined in this handbook.
This handbook will be subject to continued revision, expansion, and updating. The processing guidance in this handbook covers both Automated Commercial System (ACS) and Automated Commercial Environment (ACE) RLF entries. Additional processing guidance for ACE entries can be found in the ACE Business Rules and Process document.
This handbook serves as the primary reference guide for all EIP and RLF participants involved with transmitting EIP/RLF entries.
Brokers or self-filers who have Automated Broker Interface (ABI) capabilities and the Automated Invoice Interface (AII) module may apply to participate in EIP. EIP entries are filed in the same port where the filer is located and has the required broker permit. A CBP client representative, who evaluates the software transmissions, must evaluate each filer's AII capability. Once the testing process is completed, filers may begin to transmit live AII entries within the locally permitted port. See Appendix D EIP Harmonized Operational Approval Test Package for more guidance regarding electronic invoice testing. AII data represent electronic invoices that are linked to both entry for cargo release and entry summary for payments. AII enables an EIP/entry summary to be an electronic process. 19 C.F.R. § 143 Subparts D and E govern electronic entry filings and RLF.
Pursuant to 19 C.F.R. § 143.43 filers transmitting entry/entry summary data to parts outside of their permitted port must meet the following criteria:
Requests to participate in RLF shall be made to the assigned CBP client representative. The CBP client representative at the Office of International Trade will validate that filers meet the system eligibility requirements for the RLF program. Approved filers will be set up in the ABI system. Denied filers will be informed of missing requirements and may re-apply once the requirements are met for the RLF program. The RLF statutory requirements are codified at 19 U.S.C. § 1414; see also http://www.cbp.gov/xp/cgov/trade/trade_programs/remote_location_filing/. Pursuant to 19 C.F.R § 143.2(b) for a list of all RLF-operational locations is available for viewing online at http://www.cbp.gov/xp/cgov/trade/trade_programs/remote_location_filing/.
The electronic entry program consists of various components, all supported by an electronic invoice capability called the “Automated Invoice Interface” (AII in ACS) module. Title 19 C.F.R. § 143, Subparts D and E govern electronic entry filing and RLF.
As of the date of this publication, only entry types 01, 03 (ACE only), and 11 may be filed via EIP/RLF. The entry types permitted to be filed via EIP/RLF may expand based on system and policy modernization. If a filer transmits an EIP/RLF entry type that is not permitted at time of cargo processing, CBP will reject the entry back to the filer. For a list of entry types that may be filed via RLF, see 19 C.F.R. § 143.44(c) or http://www.cbp.gov/xp/cgov/trade/trade_programs/remote_location_filing/. In addition, single transaction bonds may not be used for EIP/RLF entries, because they cannot be filed or obligated electronically. A single transaction bond may be filed in lieu of cash deposit for EIP/RLF AD/CVD entry type “03” entry summaries. For additional information about processing ACE AD/CVD entry summaries and single transaction bonds, please see the ACE Business Rules and Process document.
Electronic invoice program participants are responsible for understanding the electronic entry program fundamentals required by CBP regulations, including the transmission of the electronic invoices. CBP will provide the informed compliance direction in order to promote trade compliance. Failure of a filer to adhere to informed compliance measures will result in CBP taking enforced compliance action(s).
CBP communicates EIP/RLF program updates to the trade via the Cargo Systems Messaging Service. These messages are located on the CBP.gov website at Cargo System Messaging Service (CSMS). CSMS is a searchable database, and messages may be retrieved based on a combination of key words and group filters. CSMS is augmented by an e-mail subscription service, which provides timely notification of new messages.
CBP accepts electronic invoice information through two electronic means, Automated Invoice Interface (AII) and Electronic Data Interchange for Administration, Commerce, and Transport (EDIFACT). The AII module and EDIFACT formats are what enable EIP/RLF to be an electronic process.
The most common method for transmitting invoice information is through the AII. A filer sends the electronic invoice information via ABI by inputting the required commercial invoice data elements in the AII module, as required by 19 C.F.R. § 141.86 through 19 C.F.R. § 141.89 and 19 C.F.R. § 142.6(a). More details about AII are covered in section 3.0.
The EDIFACT format is another option to transmit CBP Forms 3461 and 7501, and invoice information, which is a standard that has been accepted by the United Nations as an international syntax. EDIFACT contains information pertaining to business transactions of retailers, bankers, insurers, freight forwarders and many other parties.
Entry summaries filed EIP/RLF share the same electronic invoice for both cargo release and entry summary processing. Please note: Invoice numbers are not to be recycled, because it creates confusion for CBP officers, entry, and import specialists as to the accuracy of the electronic invoice data.
AII or EDIFACT will be used to transmit electronic invoices for ACE entry summaries. The EIP/RLF electronic invoice or AII is not functional in ACE; however, ACE will continue to interface with the AII module in ACS, according to current Automated Broker Interface (ABI) instructions found in the Customs and Trade Automated Interface Requirements (CATAIR). ACE entry summaries filed via RLF are subject to the same statutory and regulatory requirements that govern ACS EIP/RLF entry summaries (19 U.S.C. § 1414 and 19 C.F.R. § 143, Subpart E).
CBP electronically communicates transmission acknowledgement information to filers using ABI. The acknowledgement output message will indicate whether the AII transaction has been accepted or rejected.
Once an entry is transmitted, edits and validations are performed for basic syntax errors in the AII records, including missing data elements in mandatory records or fields. If an error is an invoice identification error (invoicing party ID/invoice number), or a record structure or sequence error, no further processing will occur on that invoice. If an error is a data error, the processing of the invoice will continue, and an error detail record will be generated for each error.
Once all individual errors have been identified for a particular invoice, a final record will be generated indicating that the invoice has been rejected. The edit features and error messages should not be used to measure data adequacy and what errors were detected of the transmitted data for CBP purposes.
The filer is obligated to inform CBP at the time of entry that a bind ruling exists on the merchandise. These rulings may be found on CBP.gov under Cross Rulings Online Search System (CROSS).
The filer may file an Invoice by Request (INVREQ) in lieu of an invoice, except in the following cases:
Note: The INVREQ option does not apply to ACE entry summary transmissions. For guidance on Electronic Invoice Processing for ACE entry summaries, see the ACE Business Rules and Process Document.
For EIP/RLF entry summary and invoice filing timeframes see section 5.5.
If an entry requires an invoice prior to release, the filer will receive a message via ABI stating, “Electronic invoice required”. All associated invoices must successfully be transmitted prior to officers viewing the entry.
If the entry summary is final, selectivity status is not bypass, i.e., “paperless”, an electronic invoice is required for CBP processing. This is indicated on the preliminary ACH statement as a new column titled “I” (Invoice) between the “TP” and “ST” columns. If an invoice is required, the value “Z” will be displayed in this column. If the invoice has already been transmitted, there is no need to transmit it a second time.
For EIP/RLF entry summary and invoice filing timeframes see section 5.5.
The purpose of the AII module is to provide documentation in an electronic format that replicates all the required data elements of a commercial invoice. AII is limited by what documents are supported by ACS and ACE. Original paper documentation presented to CBP as a condition of release of the cargo or the filing of an entry summary (license, permit, certificate, etc.) cannot be used in lieu of the AII module; however, some documents may be presented as part of the hybrid process covered in section 4.2 or as a follow-up for exam and review purposes. This chapter is dedicated to demonstrating the AII features, which exclusively support EIP/RLF.
Filers should note that the AII data must contain sufficient information for Customs to determine the value, tariff classification, and admissibility of the imported merchandise. For more information on CBP invoicing requirements, see 19 U.S.C. § 1481, 19 C.F.R. § 141.81 through 19 C.F.R. § 141.83, 19 C.F.R. § 141.85 through 19 C.F.R. § 141.87, 19 C.F.R. § 142.6, and 19 C.F.R. § 143.36.
CBP issued rulings assist the importer in determining the correct classification for the merchandise, which may exempt the importer from transmitting an electronic invoice, depending on what information CBP requires.
C = A pre-classification number, specifically citing the importer and merchandise, is provided in the ruling number.
R = A binding ruling number is provided in the ruling number.
Ruling Number: The administrative number assigned by CBP to a binding ruling or a ruling under the pre-importation review program (PIRP).
Supplier Party ID Code: A code representing the supplier party. This code is based on the supplier’s name and address and is derived the same way as the Manufacturer/Supplier Code and the Manufacturer/Shipper Code.
Invoice Number: The invoice number. Valid characters are alpha, numeric and dash (-) only.
Invoice Date: A numeric date in MMDDYY (month, day, year) format representing the invoice date.
Invoice Type: A code representing the invoice type. Valid invoice type codes are: IN = Commercial Invoice; PI = Pro forma Invoice; CO = Corrected; CI = Consolidated Invoice; CN = Consignment.
Currency Code: A code representing the type of currency specified on the invoice. Valid currency codes are listed in Appendix B of the ABI CATAIR Appendices.
Fixed Exchange Rate Indicator: A code indicating whether the conversion rate reported in the Rate of Exchange field is fixed. A code of 1 indicates the rate is fixed via the purchase contract; 0 indicates the rate is not fixed.
Rate of Exchange: A number representing either the fixed rate of exchange or the appropriate CBP rate of exchange for the date of export as published by CBP Information Exchange (CIE). Six decimal places are implied.
Payment Terms Type: A code representing the payment terms. Valid Payment Terms Type Codes are: 01 = Basic, 02 = End of month, 03 = Fixed date, 04 = Deferred, 05 = Discount not applicable, 08 = Basic discount offered, 15 = No charge, 20 = Penalty terms, 22 = Discount terms, 99 = Other.
Terms of Payment: A narrative message describing the terms of payment of an invoice. If a Designated Exam Site (DES) is requested, you must provide the DES FIRMS code within the first 30 characters of this field in position 6-75 of the C02 record of the AII transmission. See CSMS Message #11-000031.
Number of Shipping Units: The number of outermost shipping units for the type of shipping unit reported.
Type of Shipping Unit: A code representing the type of shipping unit. Valid shipping unit codes are listed in Appendix B of the ABI CATAIR Appendices.
Shipping Unit Identity: The identifying reference located on the shipping unit that is being reported (e.g., ABCD01234567 for a container).
Part Package Indicator: A code indicating whether the shipping unit is partially or entirely used for the invoice. A code of 1 indicates that only part of the shipping unit is covered by the invoice. A code of 0 (zero) indicates that the entire shipping unit is covered by the invoice.
Packaging Unit Identity: The identifying reference of the unit packed immediately within the shipping unit identified in Part Package Indicator field.
Shipping Symbol Description: Free-form description of Shipping Symbol. For example, initials 'Z.K.M.' inside Diamond.
Marks & Numbers: Free-form text, which describes, in full, the Shipping Marks & Numbers found on the outside of the shipping unit identified in Packaging Unit Identity field.
Party Qualifier: A code indicating a type of invoice party reported. For each invoice codes SU, UC, and IM are mandatory.
Valid Party Qualifier Codes are: AB = Buying Agent, BY = Buyer, CB = CBP Broker, EX = Exporter, II = Invoicer, IM = Importer, MF = Manufacturer, SE = Seller, SR = Selling Agent, SU = Supplier, and UC = Ultimate Consignee.
Codes BY and SE are mandatory if they differ from the UC and SU, respectively. If BY and SE are not reported and the invoice does not reflect a consignment (CN), it is assumed that the BY and SE are identical to the UC and SU. The II code is conditional. Use the II code only when the invoicing party number is different than the supplier (SU) party number.
Party Name: The name of the invoice party being reported.
Address Line One: The first line of the invoice party's address (i.e., street number and street name or post office box number).
Address Line Two: The second line of the invoice party's address.
City: The city portion of the address where the invoice party is located.
Country: The International Organization for Standardization (ISO) country code representing the country portion of the address of the invoice party. Valid ISO codes are listed in Appendix B of the ABI CATAIR Appendices.
Terms of Delivery Code: A code representing the terms of delivery for the merchandise on an invoice. Valid Terms of Delivery Codes:
FOA FOB Airport
FOB Free on Board
FOR Free on Rail
FOT Free on Truck
FPC Free Pipeline Connection
Location Qualifier: A code indicating the type of location referenced by the terms of delivery. Valid Location Qualifier Codes are shown below with its corresponding terms of delivery:
| Code | Qualifier | Terms of Delivery |
|---|---|---|
| LB | Place of Delivery | DAF, DDP, FPC |
| LC | Place of Departure | EXW |
| LI | Port of Discharge | CAI, CAF, CIF, DDP |
| LJ | Port of Loading | EXQ, FAS, FOA, FOB, FOR, FOT |
Location Code Indicator: A code indicating the document used to determine the location code. Valid Location Code Indicators are: 25 = Census, Schedule K (Foreign Ports of Lading), 26 = Census, Schedule D (U.S. Ports of Entry), and 66 = International Organization for Standardization (ISO) country code. Census Schedule K and D codes can be queried through the Extract Reference File and valid ISO codes are listed in Appendix B of the ACE ABI CATAIR.
Allowance/Charge/Adjustment Indicator: A code representing the allowance/charge/adjustment. Allowances allow for reductions in the entered value for items such as damaged or defective goods; charges are costs charged to the buyer by the seller such as testing, quota, financing, foreign inland freight, and assembly.
Valid Allowance/Charge Indicator Codes are: A = Dutiable Allowance, C = Dutiable Charge, D = Dutiable CBP Adjustment, N = Non-dutiable CBP Adjustment, R = Non-dutiable Allowance, S = Non-dutiable Charge.
In preparing invoices that include additions, deductions or both, the allowance/charge indicator should be: A, C, or D for additions to the invoice value; N, R, or S for deductions to the invoice value. Invoiced allowances detail how the amount the buyer paid the seller was different from the invoiced merchandise value. For example, allowances provide for a reduction in the dutiable value for costs associated with damaged or defective goods (code R), or provide for an increase in dutiable value due to an indirect payment (code A). Invoiced charges detail amounts the buyer paid for the merchandise in addition to the invoiced cost for each item. For example, charges allow for reductions in the dutiable value for costs charged to the buyer by the seller for testing, quota costs, financing, and foreign inland freight (code S), or allow for increase in dutiable value for dies, molds, tools, foreign research and development, etc. (code C).
Adjustments are costs or values that do not change the amount the buyer paid the seller but that adjust the dutiable value. For example, adjustments include terms of sale deductions such as international freight and insurance (code N) or allow for an increase in the dutiable value for amounts paid to a party other than the invoicing party (e.g., an assist for tooling paid to third party) (code D).
Allowances allow for reductions in the entered value for items such as damaged or defective goods; charges are costs charged to the buyer by the seller such as testing, quota, financing, foreign inland freight, and assembly.
Allowance/Charge/Adjustment Amount: The total monetary value of the allowance/charge/adjustment described. Four decimal places are implied. The guidance provided above is in no way intended to rule on whether a cost is dutiable or non-dutiable. Additional guidance is provided in 19 C.F.R. § 141.86 and 19 C.F.R. § 152.103.
Note: Allowance/Charge/Adjustment Indicators and Amounts may be transmitted at the header level or line level. Transmitting these data elements at both levels will duplicate the value of the allowance, charge, or adjustment, which will affect the accuracy of the dutiable value.
Allowance/Charge/Adjustment Description: A concise narrative description of the allowance/charge/adjustment that is being reported. Abbreviated descriptions e.g. NDC, C&F, Discount, Ins, Cost, or DDP are not acceptable. Descriptions should be itemized and spelled out, e.g., Packing, Freight, Insurance, etc.
Related Document Identifier: A valid code representing the related document identifier listed in Appendix B of the ABI CATAIR Appendices. Not all codes listed in the Appendix have been authorized to certify the source document for EIP/RLF. Some OGA certifications may not fit in the “Related Document” screen, so must be transmitted in the merchandise description field instead. More information regarding other government agency declarations and certifications are located on the EIP/RLF CBP.gov web page and in the administrative messages database.
Related Document Number: The identifying number or code associated with the license, certificate, or document being referenced in the Related Document Identifier field.
Invoice Line Number: A sequential number from 0001 to 9999 assigned to each invoice line item.
Quantity: The number associated with the statistical reporting unit for the invoiced line item. A zero quantity is not acceptable. If the statistical reporting unit for the invoiced line item is “X”, the actual invoiced quantity and unit of measure should be used. Four decimal places are implied.
Unit of Measure: A code representing the unit of measure associated with the data reported in the Quantity field. Valid units of measure codes are listed in Appendix C of the ABI CATAIR Appendices.
Examples of reporting quantity and unit of measure for invoice line-level information:
Harmonized Tariff Schedule (HTS) number 9503.31.0080 lists “X” as the reporting unit; however, if a line item description of “100 H-scale toy trains” is listed, 100 PCS must be reported.
HTS 6505.90.1530, with a line item description of “200 dozen hats (style 12B), 600 kilograms net weight,” 200 dozen must be the quantity reported, since the HTS has designated “dozen” as the primary reporting unit.
For certain commodities, a third quantity and unit of measure must be reported, such as raw cane sugar, HTS 1701.11; “International Sugar Degrees” must be reported in addition to the primary and secondary statistical reporting units.
Article Number: An identification number or code assigned by a supplier or buyer to similar or identical articles or products (e.g., part numbers or catalog numbers).
Unit Price: The monetary price per unit on which the invoice line total price is calculated. Four decimal places are implied.
Item Amount: The monetary amount associated with the merchandise on the invoice line. Item Amount must equal the Unit Price multiplied by the Number of Pricing Units, multiplied by the Percentage of Active Ingredient (if applicable), divided by the Unit Price Basis. Four decimal places are implied.
Unit Price Basis: The number of units to which the unit price applies. For example, if the invoice line item reads $575 per 100 dozen, 100 is the unit price basis.
Number of Pricing Units: The number of units which when multiplied by the Unit Price field gives the amount reported in the Item Amount field. Three decimal places are implied.
Percentage of Active Ingredient: If applicable, the percentage of a specified material in a total product. This percentage is often cited for certain chemical products. If it is pertinent to the unit price, this percentage is multiplied by the product of Unit Price and Number of Pricing Units to arrive at the line item amount. Six decimal places are implied.
Merchandise Description: The free-form text field used to record the description of the imported merchandise. The filer is responsible for providing a detailed merchandise description. The level of detail on the invoice must meet the standards specified in 19 C.F.R. § 141.86 through 19 C.F.R. § 141.89, 19 C.F.R. § 142.6, and 19 C.F.R. § 143.36. Filers should contact their software vendor for technical assistance when this additional information is missing from the transmission. Due to space limitations, some OGA certifications and declarations may not fit in the “Related Document” screen and must be transmitted in this field. Additional information regarding other government agency declarations and certifications are located on the EIP/RLF CBP.gov web page and in the administrative messages database.
Pursuant to 19 U.S.C. § 1481(a) and 19 C.F.R. § 141.86 requires a detailed description of the merchandise using the English language, which contains adequate information for examination and determination of duties. General tariff descriptions are not acceptable. Examples of unacceptable cargo descriptions are as follows: US Goods Returned, Household Goods, Jeans, Textiles, etc. The description should include the name by which each item is known, the grade or quality, and the marks, numbers, and symbols under which sold by the seller or manufacturer to the trade in the country of exportation, together with the marks and numbers of the packages in which the merchandise is packed. Additional information for certain classes of merchandise is referenced in 19 C.F.R. § 141.89. This field is also used for authorized electronic declarations, certification, and signatures required by the other government agencies. More information regarding other government agency declarations and certifications are located on the EIP/RLF CBP.gov web page and in the administrative messages database.
ID Number Qualifier: A code representing the first ID number qualifier. Valid ID Number Qualifier Codes are BN = Serial Number, CN = Chassis Number, EE = Engine Number, and VIN = Vehicle Identification Number.
ID Number: The ID number, serial number, or similar reference number associated with a single invoiced item.
Number of Invoice Lines: A number from 0001 to 9999 representing the total number of lines included on the invoice. This total must equal the total number of invoice line number recorded at the invoice line level.
Total Invoice Value: The total U.S. dollar value of the invoice. Two decimal places are implied. The total invoice value equals the sum of the following: 1) the summary total of all invoice line values (including the net value for any allowances and charges at the line level); 2) the net total of any allowances and charges that are reported at the invoice header level (e.g., packing, delivery charges, or rebates); and 3) the total invoice amount of any non-U.S. tax paid to the supplier.
Total Value Subject To U.S. Duty: The total invoice amount (in U.S. dollars) that is subject to U.S. duty. Two decimal places are implied. Total value subject to U.S. duty equals the U.S. dollar value of the net sum of the following amounts that are reported in the Allowance/Charge/Adjustment Amount Field at the header level: All dutiable charges (C), plus all dutiable CBP adjustments (D), less all non-dutiable CBP adjustments (N), less all non-dutiable allowances (R). Add to the above, in U.S. dollar value, all monetary amounts associated with the merchandise on the invoice line recorded in the Item Amounts Field at the invoice header level, plus the U.S. dollar amount reported in the Prepayment Total Field at the invoice summary level.
Total Amount of Invoice Lines: The total of the invoice line monetary amounts, including all invoice allowances or charges offered at the invoice line level. This total must be reported in U.S. dollars. Two decimal places are implied. Note: Charges and allowances coded as D or N should not be listed in this field.
Total Invoice Additional Amount: The net U.S. dollar total of any invoice allowances and charges that are reported at the invoice header level (e.g., packing, delivery charges, or rebate). Two decimal places are implied. If the tax is a whole number, the two low-order (cents) positions contain zeros.
Negative Additional Amount Indicator: If the total allowance amount that is reported at the invoice header level is greater than the amount reported for charges at the invoice line level, report N in this field; otherwise, space fill.
Foreign Tax Amount Total: The total U.S. dollar invoice amount of any non-U.S. tax payable to the supplier. Two decimal places are implied. If the tax is a whole number, the two low-order (cents) positions contain zeros.
Prepayment Total: The total U.S. dollar amount prepaid and unaccounted for on the invoice. Two decimal places are implied. If the tax is a whole number, the two low-order (cents) positions contain zeros.
Declaration of Importer or Authorized Agent: A code of X acknowledges the declaration. The Declaration Statement of Importer or Authorized Agent is:
“In the case of merchandise purchased or agreed to be purchased, I declare that the prices set forth herein accurately reflect the prices set forth in the commercial invoice, and that such prices are true. In the case of merchandise secured otherwise than by purchase agreement to purchase, I declare that the price or value statements in this filing accurately reflect the prices and values set forth in the invoice and are true to the best of my knowledge and belief. In addition, I declare that all other statements within this electronic invoice transmission accurately reflect all other statements set forth in the commercial invoice and are true and correct. Finally, I will immediately provide to the appropriate CBP officer any invoice, paper, letter, document or information maintained in any media showing that any such prices or statements are not true or correct”.
Declarant: The name of the person authorized to declare the veracity of the invoiced data. CBP strongly recommends that the broker/filer provide a telephone number this field as well.
Title of Declarant: A code identifying the position of the person validating the invoiced data to CBP. Valid Title of Declarant Codes: IR = Importer and CB = Broker.
Signature: A code of “X” denotes the electronic signature is that of the declarant.
Date of Declaration: A numeric date format representing the date of the declaration by an importer or agent.
Since RLF was intended to be an electronic process, original paper documentation presented to CBP as a condition of release of the cargo or the filing of an entry summary (license, permit, certificate, etc.) cannot be used in lieu of the All module. ABI processes CBP holds and release notifications for electronic entries in the same manner as paper entries.
Please note: If the merchandise is located at the port of unlading (POU), but the entry is filed at a different port the merchandise must remain at the POU until CBP releases it in the Automated Manifest System (AMS). However, the merchandise may move in-bond from the POU to the port of entry as defined in 19 C.F.R. § 101.1.
CBP will not process an EIP/RLF entry while an importer or consignee is on sanction for delinquent bills on ACH credit and is not set up for ACH debit (see section 5.1). The filer must cancel the electronic entry and revert to the paper entry process.
Filers should note that technical problems may prevent an entry from being processed. The cause may be an invoice number mismatch or other transmission problem. The local port RLF Problem Resolution Section (if available) or CBP client representative can help troubleshoot the problem to resolve system-related issue(s).
Please note that invoice numbers are not to be recycled, because it will create confusion for CBP officers, entry, and import specialists as to the accuracy of the electronic invoice data.
Merchandise entered via EIP/RLF, as with any other cargo entering the United States, may be subject to CBP examination. The importer or its designated agent is responsible for arranging to present merchandise for examination. The electronic invoice(s) must be adequate for the examination of the merchandise and the determination of duties and for verifying the information required for statistical purposes by 19 C.F.R. § 141.61(e). The merchandise is not released until the examination is completed and a release is posted in ACS and sent to the ABI filer and the AMS carrier.
The RLF Final Rule (see Federal Register 74 Fed. Reg. 69015 (Dec. 30, 2009)) includes language to enable “alternative filing” of paper documents, if CBP cannot accept additional information electronically (see 19 U.S.C. § 1414(b) (3) (B) and 19 C.F.R. § 143.45). Although RLF was intended to be a completely electronic process, this regulation introduces a “hybrid” RLF concept. The hybrid process provides for CBP review of OGA paper documentation in conjunction with the RLF data in ACS or ACE. Since the hybrid process is subject to change, the current policy will be posted online at the following link: RLF/EIP Administrative Messages.
Implementation of RLF as a final rule, which became effective on January 29, 2010, eliminated the Port of Arrival Immediate Release and Enforcement Determination (PAIRED) program. CBP allowed a one-year grace period for importers and filers to make alternate business arrangements. See CSMS #11-000031. Use of the DES provides an option for importers who previously used the PAIRED program. It enables the filer to make a RLF entry at the destination port, and if freight is released without need of an exam, release will be allowed without the necessity of an authorized in-bond movement.
When a filer transmits a port code in the DES field of their RLF entry summary transmission, that code is the electronic indication that the filer wants to use the “DES option” to make entry from a location other than where the freight is unladen. In addition, the transmission will indicate the port at which the trade requests that a CBP examination will occur (when applicable). Further, the filer will indicate a DES FIRMS code within the port limits at the chosen port of entry within the electronic invoice transmission.
The DES option may only be used for entries filed via RLF as specified in 19 U.S.C. § 1414.
1. The destination port code in the 30 record, position 40-43, of the Entry Summary ABI transmission.
2. The transmission of the DES FIRMS code within the first 30 characters of the “Terms of Payment” field in position 6-75 of the C02 record of the AII transmission. Please note that there are 70 characters available in this field.
- RLF filers choosing the “DES option” must transmit the AII invoices in addition to the entry data for each entry regardless of CBP selectivity.
RLF regulations require that the broker or importer direct the payment of RLF transactions using the Automated Clearing House (ACH) or other electronic payment by CBP [see 19 C.F.R. § 143.44 (b)]. Payment via currency or any monetary instrument pursuant to 19 C.F.R. § 24.1 (a)(1)-(7) is prohibited, and CBP must refuse the collection of such transactions, except for post-entry amendments, post-summary corrections prior disclosures or a port approved entry summary removal from statement. Otherwise, an EIP/RLF entry summary must revert to paper if payment of duties, taxes, and fees is made using currency or any monetary instrument. In addition, CBP will issue a warning letter to the filer for the infraction. See chapter 6 for more information about addressing instances of RLF non-compliance.
The filer may move an RLF entry from one statement to another statement (see 19 C.F.R. § 24.25), as long as the electronic payment is made timely pursuant to 19 C.F.R. § 24.25(c) (3). However, there are circumstances under which the RLF entry must be removed from the ABI statement, including cases of a duplicate entry or when the importer refuses to pay the broker for the duties, taxes, and fees. In these cases, the following steps will be used:
○ If the importer subsequently chooses to pay the duties on this entry summary, the port may accept payment on the entry via single pay.
If the RLF entry does not meet the requirements to request deletion of the entry from statement, then the filer must facilitate a second entry summary with a locally permitted filer and CBP will cancel the RLF entry as a “duplicate.” It is also important to note that if the filer uses RLF to make entry where they also have a local permit, the filer should retransmit the entry summary without the RLF flags and treat the entry summary as a locally filed ABI entry.
A filer may not pay via ACH when the Office of Administration/Revenue Division (OA) deactivates the Payer Identification Number or Payer Unit Number. However, the filer may arrange electronic payments via ACH credit with OA.
More information on ACH can be found at the following link:
http://www.cbp.gov/xp/cgov/trade/automated/automated_systems/ach/
If CBP discovers at time of entry summary processing, that an electronic entry is ineligible to be filed via EIP/RLF; the entry summary will be rejected.
If the entry summary is beyond the rejection timeframe, ports will initiate a warning letter advising the filer that the entries are ineligible to be filed EIP/RLF. The port will make the necessary corrections in ACE or ACS and request a constructed paper copy of the entry from the broker.
Remote filers (other than self-filers) not permitted in the port of entry where entry is being filed must obtain the services of a locally permitted broker to file a replacement entry. A self-filer, or a filer who is locally permitted in the port of entry, may use the original entry number to retransmit the entry summary data without the EIP/RLF flags. After removing the entry from the AII module, the paper entry package must be presented to the CBP port where the original entry was filed.
In situations where CBP cancels an entry summary filed by a locally permitted broker using the entry substitution method; the replacement entry may not be filed by a RLF filer, since RLF entries must be certified for cargo release.
Post entry amendments and protests on EIP/RLF entries are processed in the same manner as other entries. When the reviewing team receives the PEA or protest package, the entry summary and invoice information should be reviewed in ACS. If the protested information is not available in CBP automated systems, the filer must provide the information in paper form.
More information on PEAs is located at the following link:
http://www.cbp.gov/xp/cgov/trade/trade_programs/entry_summary/general_pea/pea_modification.xml.
Corrections to ACE EIP/RLF entry summaries must be made via the post-summary correction (PSC) process. PSC allows the trade to make electronic corrections via ABI to an existing entry summary. See the ACE Business Rules and Process document for further information about PSC.
AD/CVD entry summaries may now be transmitted via EIP/RLF in ACE. Additional guidance on processing ACE entry type 03 entries is located in the ACE Business Rules and Process Document. Please note that for all ACE type 03 entries, paper reimbursement certificates are acceptable but not encouraged. Filers should use the non-reimbursement statement functionality in ACE.
If an entry summary is designated by CBP for team review or has an ABI-generated Census warning, a filer will have two working days from the date of the “accepted—records required” ABI message to transmit electronically and free of error all invoice(s) associated with the entry. See CSMS #99-000494.
If an entry summary is rejected, a filer has two working days after the date of rejection to transmit the electronic invoice(s).
The EIP/RLF program is intended to be an entirely electronic process; however, there are exceptions to the policy. Supporting documentation may be requested via a CBP Form 28 (Request for Information) or a demand letter for further review post summary. The AII module, in combination with other ACS or ACE data, should contain the necessary information to process the entry summary. Failure to respond to a demand letter will result in a penalty action under 19 U.S.C. § 1509 for recordkeeping violation.
EIP/RLF filers (brokers or importers of record) are required to comply with the statutory (19 U.S.C. § 1414) and regulatory (19 C.F.R. § 143, Subpart E) requirements of the RLF Program, as well the electronic entry filing requirements (19 C.F.R. § 143, Subpart D).
EIP/RLF transactions constitute “customs business” as defined in 19 U.S.C. § 1641 and 19 C.F.R. § 111, and brokers must comply with pertinent requirements in those provisions.
19 U.S.C. § 1484 requires an importer of record using reasonable care to make entry by filing such information as is necessary to enable CBP to determine whether the merchandise may be released from Customs custody, and using reasonable care, to complete the entry by filing with CBP the declared value, classification and rate of duty and such other documentation or information as is necessary to enable CBP to properly assess duties, collect accurate statistics, and determine whether any other applicable requirement of law is met. The “reasonable care” standard extends to information and documentation submitted through EIP/RLF.
EIP/RLF is an elective method of making entry. It is important to keep in mind that, notwithstanding unique filing issues, CBP’s response to a violation involving entries filed. EIP/RLF should generally be the same as the response that CBP would take if EIP/RLF entries were not involved.
A claim for liquidated damages for EIP/RLF entries may be initiated when the entry summary in proper form is filed late or not filed, or other conditions of the basic importation and entry bond are not met. These conditions are found at 19 C.F.R. § 113.62. The principal and surety are jointly and severally liable for payment of duties, taxes and charges under the bond and for reimbursement and exoneration of the United States. The bond principal (the importer of record) is responsible for satisfying all other conditions of the bond.
EIP/RLF entries must be secured with a continuous bond. See 19 C.F.R. § 143.43(c). This continuous bond is an activity code 1 bond (a basic importation and entry bond) on which the importer of record is the principal.
Brokers that fail to comply with the requirements of EIP/RLF may be penalized under 19 U.S.C. § 1641 or, when circumstances warrant, under 19 U.S.C. § 1592. Importers of record may be penalized under 19 U.S.C. § 1592 if circumstances warrant. Both brokers and importers may be penalized for recordkeeping violations involving RLF transactions.
Chapter 15 of the CBP Broker Management Handbook sets forth general broker penalty procedures. Under those procedures, CBP's response to a broker violation depends on whether it is egregious (flagrant) or non-egregious.
Non-egregious violations are generally considered non-repetitive clerical mistakes, or a good faith oversight on the part of a broker, an employee of the broker, or a self-filing importer of record. In the case of non-egregious violations, CBP will first attempt to work with the broker through the informed compliance process of communication and education. This is an attempt to improve the broker's performance. A penalty, or penalties, should only be assessed after the non-punitive approach fails to produce satisfactory corrective action. In regard to non-egregious violations, brokers will be clearly informed in writing of any unacceptable performance and given a reasonable opportunity to improve those deficiencies. An egregious violation is an act or omission that shows irresponsibility beyond that of a non-repetitive clerical mistake or a good-faith oversight.
Communicating the deficiency to the broker and advising them to take corrective action is generally the first step in the informed compliance process. The amount and type of communication about a particular deficiency depends on the facts of the case. In cases of EIP entries filed in the port where the filer is located, ports may communicate with the broker in-person by calling the broker into the office to discuss the issue, or initiating a broker interview at the broker's premises. In cases of EIP/RLF entries, because of the broker's remote location, communication will generally be by telephone.
If step one does not correct or resolve the issue (or the broker cannot be contacted), the deficiency is communicated to the broker via a warning letter which advises the broker of the deficiency and demands improved performance and/or other specific corrective action
If the warning letter does not correct the issue, a penalty action(s), or actions, is/are initiated. This should generally be done within one year of the warning letter. Prior to the actual issuance of each penalty, a pre-penalty notice must be issued by CBP. Ports should work with the broker's client representative and national account manager (where applicable) during the informed compliance process.
The following are examples of non-egregious violations directly related to EIP/RLF filing:
Brokers or importers of record may be penalized under 19 U.S.C. § 1592 if circumstances warrant. See 19 C.F.R. Pt. 171, App. B, (K) for guidance on the assessment of 19 U.S.C. § 1592 against brokers.
Pursuant to 19 U.S.C. § 1509 and 19 C.F.R. § 143.39 and 19 C.F.R. § 163.6, brokers and importers who do not produce entry records requested through a lawful demand are liable for penalties of up to $100,000 for each release of merchandise. Recordkeeping violations are generally assessed against brokers under 19 U.S.C. § 1641 not 19 U.S.C. § 1509.
Note: Requests for documents shall be made using the CBP Form 28.
Guidance on obtaining a national permit is located in 19 C.F.R. § 111.19(f). A filer applying for a national permit must first have a district permit issued under 19 C.F.R. § 111.19(a) or (e). Self-filers are not required to obtain a national permit.
No. You must provide your full name or the name of the business that is accepting the veracity of the submitted data. CBP strongly recommends that you provide a telephone number in this field to facilitate communications to you by CBP personnel concerning your EIP/RLF entry status.
No. Only entry types 01, 03 and 11 are accepted at this time. CBP is looking to expand to other entry types in the future.
If the broker transmitted the wrong port code for the port of entry, the entry should be cancelled and a new EIP or RLF entry with a new entry number transmitted. However, it is important to note that a broker may correct the port of unlading field using the “Bill of Lading Update” function.
Carrier Code, Master/House/Sub-house bill numbers, date of arrival, port of unlading, quantity and units of measure, voyage/flight/trip number, FIRMS code and EDA are the only elements that can be updated via a broker’s bill of lading update transmission in ABI.
Currently, all EPA declarations are made in the commercial description field in the “Invoice Line Detail” screen of the AII.
In addition, the Toxic Substances Control Act (TSCA) statement must include a 'TSCA +' or 'TSCA –' indicator for positive or negative certification for shipments subject or not subject to TSCA, along with the name of the authorized individual or declarant.
The engine declaration includes the following:
1. Name of the EPA form used which will be a 3520-1 or 3520-21
2. A plus “+” or “–” to indicate positive or negative certification for shipments requiring or not requiring EPA Form 3520-1 and/or 3520-21, and
3. The appropriate alphanumeric code associated with the EPA form/s used.
EPA does not authorize releases via EIP/RLF of Independent Commercial Importer (ICI) imports using codes A, C, J and Z found on EPA Form 3520-1.
The declaration (EPA Form 3520-21) guidance can be found in the Cargo Systems Messaging Service (CSMS) under messages 99-001068 (EIP/RLF and TSCA Memorandum) and 08-000121 (EIP/RLF Transmission of EPA Documentation – Revised Message).
All rules, regulations, and requirements, including those of other government agencies, must be in compliance. If the filer has not included the appropriate OGA data 9 (EPA 3540-1, 3520-1, or TSCA certification) in its invoice transmission, the reviewing officer should inform the filer of this omission. The filer will need to provide the missing data in a retransmission of the invoice. The filer should contact its assigned CBP client representative for information on correcting data in a previously transmitted electronic invoice.
Note: Entries that require the physical presentation of any paper document for CBP or any PGA may not be sent via RLF/EIP transmission.
No. EIP/RLF may not be filed at an express consignment facility. See 19 C.F.R. § 128.1(e).
No. All adjustments, discounts, charges; including allowances must be fully notated and itemized. Descriptions such as MMV, CFR, INS, FRT, etc…are not allowed. See 19 C.F.R. § 141.86.
No. Under 19 C.F.R. § 111.2(b) (2) (D) once an entry summary has been accepted by CBP, a broker with a national permit who did not file the entry may represent the importer of record before CBP or on any issue arising out of the entry or concerning the merchandise covered by that entry, upon request by CBP, the broker must submit appropriate evidence of the right to represent the client on the matter at issue.
Please refer to the following link for the most up-to-date administrative messages:
http://www.cbp.gov/xp/cgov/trade/trade_programs/remote_location_filing/operational_notes/rlf_eip.xml
12-000482 Guidance Regarding Removal of Remote Location Filing (RLF) Entry from an ABI statement
12-000281 EIP/RLF Hybrid Ineligible Forms List Update
12-000054 Changes to the RLF Application Process
11-000178 Remote Location Filing (RLF) Hybrid Policy
11-000031 PAIRED Program Expiration on January 28, 2011
10-000295 EIP/RLF Invoice by Request Allowed on Truck Shipments
10-000123 Textile Declaration No Longer Required On EIP/RLF Entries
10-000122 New Remote Location Filing (RLF) Ports Added
10-000071 ACS Entry Summaries not receiving Notification of Failed Paperless Status
10-000026 Remote Location Filing (RLF) Final Rule and Grace Period
10-000020 Personal Effects and Household Goods filed via Electronic Invoice Program (EIP)/Remote Location Filing (RLF)
10-000002 Remote Location Filing - Final Rule
08-000352 Interim Guidelines for Entering Merchandise Transported via Pipelines
08-000121 EIP/RLF Transmission of EPA Documentation – Revised Message
08-000003 More Info on New Administrative Message System
07-000246 New Administrative Message Process
07-000132 RLF/EIP Electronic Document Reminder
07-000102 All Invoice Entry Summary Correlation
07-000012 Remote Filing of Canadian Softwood Lumber Entries
06-000871 EU Pasta Entries not Allowed under EIP/RLF
06-000378 Actual Use Entries not Allowed Under EIP/RLF
05-000486 In-bonds
04-002320 Government Entries not Allowed EIP/RLF
04-002319 Electronic Invoice Reminder
04-002223 Terms of Sale
04-001899 Deletion of 7501, Statement Processing, Census Rejects
04-001623 Terms of Sale
04-001500 Preparing Electronic Invoices, Terms of Sale
02-000778 RLF/EIP Invoice by Request Reminder
02-000488 Steel Entries
01-000957 National Permit Required
01-000785 Rejection of Entries Policy
00-000514 ABI Changes to Statement Update Function
99-001068 EIP/RLF and TSCA Memorandum
| 99-000494 | When an Electronic Invoice is Required |
|---|---|
| 98-000476 | RLF/EIP Release Process |
| 98-000403 | RLF/EIP Invoice by Request Process |
| 98-000104 | RLF/EIP ABI Messaging Change |
| 97-001104 | RLF/EIP ATF Documentation for Alcohol Shipments |
| 97-001001 | RLF Information on the World Wide Web (http://www.cbp.gov) |
| 97-000857 | RLF/EIP Invoice-by-Request Feature |
| 95-000800 | Implementation Date of No Slashes |
| 95-000552 | No Slashes “\” in the Supplier Invoice Number |
| 95-000158 | EIP Rejected Entry Summary Procedures |
| 94-001078 | All Changes |
| 94-000496 | Rejects and Census Warnings |
| 94-000497 | Changes to 42/43 Records |
| 93-000821 | Submission of Paper on Electronic Summaries |
| 93-000801 | Submission of Paper on Electronic Summaries |
| 93-000767 | 42 and 43 Record Relationships |
| 93-000458 | Paper Statements for ACH Paid EIP/RLF |
Remote Location Filing Regulation (19 C.F.R. § 143, Subpart E)
Remote Location Final Rule. 74 Fed. Reg. 69015 (Dec. 30, 2009).
http://www.cbp.gov/xp/cgov/toolbox/contacts/ports/
Automated Broker Interface (ABI) – A component of CBP’s Automated Commercial System (ACS) that permits qualified participants to electronically file required import data. ABI is a voluntary program available to brokers, importers, carriers, port authorities, and independent service centers.
Automated Clearing House (ACH) – The electronic payment option that allows participants to pay, and or receive CBP duties, taxes and fees electronically. See also, 19 C.F.R. § 24.25.
Automated Commercial System (ACS) - The Automated Commercial System is the comprehensive electronic system used by CBP to track, control, and process all commercial goods imported into the United States.
Automated Commercial Environment (ACE) - The Automated Commercial Environment (ACE) is the United States’ commercial trade processing system designed to automate border processing, to enhance border security and foster our Nation’s economic security through lawful international trade and travel. ACE will eventually replace the current import processing system for U.S. Customs and Border Protection (CBP), the Automated Commercial System (ACS). ACE is part of a multi-year CBP modernization effort that is being deployed in phases. ACE provides a solid technology foundation for all border security initiatives within CBP and will:
Automated Invoice Interface (AII) – The system that allows filers to send electronic invoice information to CBP. This information is transmitted using either ABI record formats or the EDIFACT CUSDEC (Customs declaration). When EDIFACT is used, the filer also transmits data that is normally on the CBP Form 3461 for cargo release, as well as the entry summary, invoice data, and other government agency data. See 19 C.F.R. § 143.32(c)(h).
Cargo System Messaging Service (CSMS) – The searchable database of messages that are of interest to ABI Filers, ACE Event Participants, ACE Portal Accounts, ACE Reports Users, Air Carriers, Ocean Carriers, Periodic Monthly Statement Participants, Rail Carriers and Truck Carriers. CSMS messages can be retrieved based on a combination of keywords and filtering by
group. CSMS provides the added feature of cross-referencing messages from the initial search result set with related message counterparts, sorting by publish date, title and CSMS number.
Certification – The electronic equivalent of a signature for data transmitted through ABI. This electronic (facsimile) signature must be transmitted as part of the immediate delivery, entry or entry summary data. Such data are referred to as “certified”. See 19 C.F.R. § 143.32(e).
Centralized Exam Station (CES) – Local port examination site under the jurisdiction of a port director, which has been authorized as the “central examination location” for the port in lieu of the physical location of the cargo. This also may mean “cargo exam site”. See 19 C.F.R. § 118.1.
Demand Letter – A letter to the broker and importer requiring invoices and supporting documents related to an entry to be transmitted to CBP in pursuant to 19 USC 1509 and 19 C.F.R. § 163.6. Brokers and importers who do not produce records requested by CBP are liable for penalties, including recordkeeping penalties for each release of merchandise of up to $100,000 pursuant to 19 U.S.C. § 1509 and 19 C.F.R. § 143.39 and 19 C.F.R. § 163.6.
Designated exam site (DES) - The port where the filer will file the entry documents and the CBP exam is to take place. DES is defined as the “Designated Examination Site” in Public Law 103-182, Title VI Customs Modernization (Mod Act). For example, if the cargo is destined for Minneapolis, and the filer would like to have the cargo exam conducted at the final destination of the cargo, Minneapolis would be the alternate or designated exam site. This option is only available for entries filed via RLF.
EDIFACT – The Electronic Data Interchange for Administration, Commerce and Transport that provides an electronic capability to transmit detailed CBP Forms 7501 and 3461, and invoice data. See 19 C.F.R. § 143.32(h).
Electronic Invoice Program (EIP) – The module of the Automated Broker Interface (ABI) that enable entry filers to transmit detailed invoice data and includes Automated Invoice Interface (AII) and any other electronic invoice authorized by CBP. This is a pre-requisite for RLF. See 19 C.F.R. § 143.32(k).
Port of arrival - The location of initial cargo arrival, or is the first port of arrival in the United States.
Port of entry processing - The port where CBP processes the entry (i.e., the CBP 3461 for release of cargo).
Port of entry summary processing - The port where CBP processes the entry summary (i.e., the CBP 7501).
Port of unlading- The port of call in which cargo shipments are discharged.
Remote filing location – The remote filer office that is responsible for preparing the entry and entry summary information. For example, if a Baltimore filer files an entry for merchandise arriving in Houston and shipped to Minneapolis, the remote filing location is Baltimore. The remote filing location should not be confused with the data processing (DP) site from which the ABI information is physically transmitted. If the filer has various offices networked to a mainframe computer located in New York, and all the ABI data is transmitted from New York, the DP site is New York, but the remote filing location is still Baltimore.
Warning Letter – An informed compliance letter notifying an EIP/RLF filer of any infraction when an entry or entry summary was filed contrary to 19 U.S.C. § 1414 and 19 C.F.R. § 143, Subpart E. It serves as a warning against future breaches of the RLF regulations and does not preclude penalty action for the above-mentioned violation(s). Future instances of non-compliance are referred to CBP Headquarters for further administrative action, which can include suspension of RLF privileges or removal from the program.
Updated 2/8/2012
Thank you for your interest in the electronic invoice program (EIP). Your CBP representative has set one of your ABI port profiles to 'test' for the automated invoice interface transmission. Completion of this test is required prior to becoming operational for EIP filing and it is completed in three stages. If Remote Location Filing (RLF) is requested it is addressed in stage four.
Create and transmit a separate invoice transaction (application code CI in the CATAIR) for each of the following test conditions.
This test is similar to the ABI entry summary testing completed when you first became an ABI filer. The data elements that are provided in stage one must be transmitted in the correct fields. All other required data fields are not specified by the test yet they must contain valid data or the transmission will reject.
| INVOICE NUMBER | 2010-1234 |
|---|---|
| TERMS OF SALE | FOB |
| ATF IMPORT PERMIT | xx-A-123 |
| ATF LABEL APPROVAL | 4000123XXX |
| ATF CERTIFICATE OF AGE | 2004-5555 |
| SEE CSMS MESSAGE # | 97-001104 FOR ADDITIONAL INFORMATION |
| DUTIABLE VALUE | $ 59,690 |
| Line | SKU | DESCRIPTION | UOM | QTY | PRICE/UOM |
|---|---|---|---|---|---|
| 1 | 269050687 | EXPENSIVE GIN 12X1L DROPIN 47% ROPP | Case | 880 | 67.83 |
Below is a list of system and user entry reminders to assist you in your future EIP filing. If any of the information requires clarification, please contact your ABI Client Representative for assistance.
1. Make sure the invoice number(s) and invoicing part(ies) on the entry summary (EI) match the invoice number(s) and invoicing part(ies) on the automated invoice (CI). Simply receiving an error free message for both does not mean the two applications matched. Failure to link all of the associated invoices means that the entry will not appear in the inspector's inbox and consequently will not be processed.
2. Make sure all lines on the EI are associated with appropriate lines on the CI. Take care to ensure there are no unassociated invoice lines. Failure to do so will mean that the reviewing CBPO will not see the associated HTS numbers when reviewing the entry and entry summary and this may complicate and delay the processing.
3. Do not transmit the EI and CI at the same time. When they are sent concurrently, ACS often fails to post the entry in the inspector's inbox.
4. Make sure that the invoicing party on the EI matches the invoicing party on the CI. Some entries require the actual manufacturer MID on the EI's 60 record which may need to be different from the invoicing party's MID on the 42 record if they are not the same parties. Some software programs default a match of those two fields. Failure to link all of the associated invoices means that the entry will not appear in the inspector's inbox and consequently will not be processed.
5. Make sure that the invoice data is correct, complete, and detailed. The original invoice can only be transmitted once. Corrections to the transmitted data can not be corrected easily after cargo selectivity has occurred. Failure to do so can mean delay and extra cost as you may be required to revert to a paper entry package.
6. Make sure you have provided sufficient invoice line descriptions. The CI line level description has to mirror the paper invoice, at minimum, but it should be enhanced if the information is insufficient for the CBPO to verify the admissibility and classification for the merchandise. Use your past experience. If the invoice says "32 cartons of toys" you would have had to contact the importer to find out what it was prior to classification and would have annotated the paper invoice with a statement similar to: "per importer, merchandise is a 12 inch doll with porcelain head." Since you would have enhanced the description in paper you should include the additional description in the electronic invoice. Failure to do so may result in delay, issuance of CF 28 and/or CF 29, and extra cost as you may be required to revert to a paper entry package.
7. Make sure you have provided the required special invoicing data. Transmission of data electronically does not exempt them from the special invoicing requirements detailed in 19 C.F.R. 141.89.
8. Transmit contact information within the Broker Party data. This is not mandatory yet it will provide the reviewing CBP officer with a way to quickly contact you if there are issues with your filing.
9. Do not send a unit of measure 'X' on the CI transmission.
10. If paper invoice has a unit price with more than four decimal places, you will need to modify the "unit" for the electronic line. Here is an example:
| Price per unit | Unit | Number of units | |||
|---|---|---|---|---|---|
| On paper invoice | 3.14557 | 1 | Kg | 100800 | $317,073.46 |
| Transmitted on electronic invoice | 31.4557 | 100 | Kg | 10080 | $317,073.46 |
11. Make sure you can receive a US message (in ACS) and/or a UC message (in ACE) and your staff knows what to do upon receipt. Failure to do so may result in liquidated damages and extra cost as you may be required to revert to a paper entry package.
12. Do not use EIP to present entry/entry summary if any paper document(s) are required. A few documents have been authorized in EIP under CSMS messages. A list of selected RLF and EIP Administrative Messages can be found at: http://www.cbp.gov/xp/cgov/import/cargo_summary/remote_location_filing/operational_notes/admin_messages/
13. Send the electronic invoice for any summary selectivity result that does not include that word "paperless." Unfortunately the entry summary selectivity response is not as clear as the cargo selectivity response. If the filer does not see the message "Paperless" at time of summary, the electronic invoice is owed.
14. In addition to best practice #13 above, it is important to review the preliminary daily statement for the 'Z' indicator in the 'I' column. This is another indicator that an electronic invoice is owed for the entry. If there is a 'Z' and you have not yet sent the electronic invoice you must transmit it at this time. See CSMS #10-000274 for additional information.
15. It may be useful to send the electronic invoice prior to EIP/RLF entry/entry summary filing for all land border shipments. It is important to note that cargo selectivity is not run on land border entries until the truck or train arrives. Therefore, if an invoice is required but not present when your truck/train attempts to cross, your cargo may not be processed until the invoice is transmitted.
16. Since EIP is a prerequisite for Remote Location Filing (RLF) participation, all of the above best practices are also necessary for RLF entries filed once approved for RLF.
---| INVOICING PARTY | TWJOYYOU1109TAI JOY YOU DEVELOPMENT BVI LTD C/O JOY ROOM 1109, NO 2 FU-HSING N RD TAIPEI TAIWAN |
| --- | --- |
| SUPPLIER | CNSUNGRO1GAO SUNVIM GROUP CO LTD NO 1 FURI ROAD GAOMI CHINA |
| MANUFACTURER | CNSUNGRO1GAO SUNVIM GROUP CO LTD NO 1 FURI ROAD GAOMI CHINA |
| INVOICE NUMBER | 62344448 |
| TERMS OF SALE | CIF Insurance $336.00 Freight $2000.00 |
| DUTIABLE VALUE | $11,431 |
| Line | SKU | DESCRIPTION | UOM | QTY | CIF PRICE /UOM | CIF LINE VALUE |
|---|---|---|---|---|---|---|
| 1 | 32009035 | 10 CUP WIDE MOUTH FOOD PROCESSOR-STAINLESS STEEL BASE 2 SPEED PULSE MOTOR DISHWASHER SAFE 10 YEAR WARRANTY | PC | 200 | 49.99 | 9998.00 |
| 2 | BL- 615856 | INFANTS GIRLS 100% COTTON KNIT BLUE T- SHIRT 175GSM, ROUND NECK, SHORT SLEEVED, HEMMED BOTTOM | DZ | 30 | 41.88 | 1256.40 |
| 3 | GR- 615856 | INFANTS GIRLS 100% COTTON KNIT GREEN T- SHIRT 175GSM, ROUND NECK, SHORT SLEEVED, HEMMED BOTTOM LAST SEASON'S COLOR | DZ | 30 | 41.88 | 1256.40 |
| 4 | RD- 615856 | INFANTS GIRLS 100% COTTON KNIT RED T-SHIRT 175GSM, ROUND NECK, SHORT SLEEVED, HEMMED BOTTOM | DZ | 30 | 41.88 | 1256.40 |
| Invoice Total | 13767.20 |
---INVOICE NUMBER 333
TERMS OF SALE C&F
Freight \$3300
C.A.S. No. 72-18-4
DUTIABLE VALUE \$787,980
POSITIVE TSCA FOR BOTH LINES SIGNED BY SUSAN SMYTHE-JONES
SEE CSMS MESSAGES 08-000062 AND 99-001068 FOR ADDITIONAL INFORMATION
| Line | SKU | DESCRIPTION | UOM | QTY | C&F PRICE/UOM | C&F Line Value |
|---|---|---|---|---|---|---|
| 1 | TA251554-1000 | L-VALINE (NUTRITIONAL) Branch Chained Amino Acid Formula 1000 CAPS/BTL; 24 BTL/CASE | CASE | 1500 | 311.76 | 467640.00 |
| 2 | TA251554-500 | L-VALINE (NUTRITIONAL) Branch Chained Amino Acid Formula 500 CAPS/BTL; 24 BTL/CASE | CASE | 1500 | 215.76 | 323640.00 |
| Total | 791280.00 |
Only after your CBP representative has indicated that you have successfully sent the three test invoices described above, may you move on to stage two. For this stage, you must transmit at least 5 more test invoices of your choice from past or current entries. There must be at least one test invoice with multiple invoice lines and one with terms of sale CIF, C&F, C&I, or DDP within the 5 invoices you choose to transmit.
Once you have successfully transmitted the 5 invoices of your choice, fax or email a scanned image of the paper invoices to your CBP representative. Your CBP representative will compare the paper invoices to the electronic transmissions to ensure that the data is being transmitted fully.
Stage two is a perfect opportunity to test your software beyond the 5 invoices requested. Successful EIP filers have used this stage to send a wide variety of electronic invoices while in the test stage. This way they can address any user or software issues without delaying or adversely affecting current shipments.
At this stage your client representative will update your ABI port profile(s) to be operational for automated invoice interface transmissions and you may begin filing complete EIP entries at your
local permitted ports. Once you have sent an entry summary flagged for EIP and the associated electronic invoice(s), the ABI client representative must confirm that your software is able to correctly match electronic entry/entry summary data to electronic invoice data.
It is important to note that many new EIP filers who are set to operational for EIP locally have difficulty matching their entry summary (EI) data to their automated invoice (CI) data. When the two transactions do not match, the entry is not processed for cargo release and it will not meet the invoice annotation requirements of 19 C.F.R. § 141.90.
Once you are sending operational electronic invoice data, continue the test process with your ABI client representative to ensure you are properly matching EI to CI at the line level.
If you are using INVREQ and the entry receives “paperless” results for both cargo and summary selectivity, you can still send in the associated electronic invoice(s). This will allow the client representative to see that the records match.
Once you have successfully transmitted local EIP entries as documented in stage three of this process, you may request to become operational to file your EIP entries remotely.
In the past there was a formal application process for RLF approval at the HQ level. The RLF application process at HQ has been discontinued now that RLF is no longer a prototype. Although there is no formal application process, the regulations (19 C.F.R. § 143.43) require that RLF filers must:
Your CBP representative may set up the ABI profile records for RLF after you have met the above requirements.
Below is a list of system and user entry reminders to assist you in your future EIP filing. If any of the information requires clarification, please contact your ABI Client Representative for assistance.
17. Make sure the invoice number(s) and invoicing part(ies) on the entry summary (EI) match the invoice number(s) and invoicing part(ies) on the automated invoice (CI). Simply receiving an error free message for both does not mean the two applications matched. Failure to link all of the associated invoices means that the entry will not appear in the inspector’s inbox and consequently will not be processed.
18. Make sure all lines on the EI are associated with appropriate lines on the CI. Take care to ensure there are no unassociated invoice lines. Failure to do so will mean that the
reviewing CBPO will not see the associated HTS numbers when reviewing the entry and entry summary and this may complicate and delay the processing.
19. Do not transmit the EI and CI at the same time. When they are sent concurrently, ACS often fails to post the entry in the inspector's inbox.
20. Make sure that the invoicing party on the EI matches the invoicing party on the CI. Some entries require the actual manufacturer MID on the EI's 60 record which may need to be different from the invoicing party's MID on the 42 record if they are not the same parties. Some software programs default a match of those two fields. Failure to link all of the associated invoices means that the entry will not appear in the inspector's inbox and consequently will not be processed.
21. Make sure that the invoice data is correct, complete, and detailed. The original invoice can only be transmitted once. If an invoice correction is needed, the filer must transmit correct invoice data using the original invoice number and adding the suffix letter "a" at the end of the invoice number. Once the corrected invoice data is successfully transmitted with this "new" invoice number, the filer must retransmit the entry summary data to reflect the "new" invoice number in the KI record. Failure to do so can mean delay and extra cost as you may be required to revert to a paper entry package.
22. Make sure you have provided sufficient invoice line descriptions. The CI line level description has to mirror the paper invoice, at minimum, but it should be enhanced if the information is insufficient for the CBPO to verify the admissibility and classification for the merchandise. Use your past experience. If the invoice says, "32 cartons of toys", you would have had to contact the importer to find out what it was prior to classification and would have annotated the paper invoice with a statement similar to: "per importer, merchandise is a 12 inch doll with porcelain head." Since you would have enhanced the description in paper, you should include the additional description in the electronic invoice. Failure to do so may result in delay, issuance of CF 28 and/or CF 29, and extra cost as you may be required to revert to a paper entry package.
23. Make sure you have provided the required special invoicing data. Transmission of data electronically does not exempt them from the special invoicing requirements detailed in 19 C.F.R. 141.89.
24. Please use the "Declarant" field on the C95 record to provide a contact name and telephone number.
25. This is not mandatory yet it will provide the reviewing CBP officer with a way to quickly contact you if there are issues with your filing.
26. Do not send a unit of measure 'X' on the CI transmission.
27. Make sure you can receive a US message and your staff knows what to do upon receipt. Failure to do so may result in liquidated damages and extra cost as you may be required to revert to a paper entry package.
28. Do not use EIP to present entry/entry summary if any paper document(s) are required. A few documents have been authorized in EIP under CSMS messages. A list of selected RLF and EIP Administrative Messages can be found at: http://www.cbp.gov/xp/cgov/import/cargo_summary/remote_location_filing/operational_notes/admin_messages/
29. Send the electronic invoice for any summary selectivity result that does not include that word “paperless.” Unfortunately, the entry summary selectivity response is not as clear as the cargo selectivity response. If the filer does not see, the message “Paperless” at time of summary the electronic invoice is owed.
30. Since EIP is a prerequisite for Remote Location Filing (RLF) participation, all of the above best practices are also necessary for RLF entries filed once approved for RLF.