By Karen E. Thuermer, AJOT No one is exactly sure when U.S. Customs and Border Patrol (CBP) will implement 100 percent electronic filing under the Automated Commercial Environment (ACE) system, but one thing is for certain: customs brokerage firms should begin implementing ACE into their business processes as soon as possible. That’s the word coming from the National Customs Brokers and Forwarders of Association of America, Inc. (NCBFAA), particularly since CBP expects to roll out new modules over the course of 2012. According to the NCBFAA, customs brokers are the most active trade users of Automated Broker Interface (ABI) and Automated Commercial System (ACS) and will, similarly, be the largest non-governmental users of the corresponding parts of ACE. Actively Involved Customs brokers file 97 percent of all customs entries. Fewer than 2,000 brokers act as agents for the more than 800,000 annual importers. In addition, many brokers represent air, ocean, rail, and truck carriers in many of their interactions with CBP. After the entry summary filing, brokers continue to handle CBP requests for information, filing of drawback entries, liquidation processing, and protests. The NCBFAA was an active participant in the initial development of ABI/ACS and has spent more than 25 years working with CBP to update and refine ACS/ACE. Consequently, the organization brought together a select committee representing a cross section of its entire industry. NCBFAA maintains that its members are the most experienced in this automation project and experts on the customs process. “Our recommendations were initially reviewed by our ACE Strategy and Automation Committees and finally approved the NCBFAA Board of Directors,” reported NCBFAA President Jeffrey Coppersmith. In an open letter to its members and the industry late last year, Coppersmith encouraged all participants to begin integrating ACE into their business processes since the corresponding old module in ACS will be decommissioned once the new module is rolled out. At that point, ACE will be the only system available for that functionality. “The NCBFAA ACE Strategy Task Group believes that it is no longer a question of whether to migrate to the Automated Commercial Environment (ACE), but when, and we believe that the time is now,” Coppersmith wrote. Some brokers, however, have been resisting implementing ACE, primarily because of the pace of its development. Some are concerned about the operational complexities and costs associated with maintaining and updating dual systems to meet ongoing CBP changes. In addition, they want to avoid creating the unlevel playing field that inevitably occurs when some brokers bear the costs of conversion to ACE and others hold back. NCBFAA is in support of this position as outlined in its White Paper on ACE, yet stresses that the implementation of ACE is a foregone conclusion and it will not be abandoned. “While much work remains to be done, CBP has recently begun to show good progress and has adopted essentially all of the recommendations for functional development outlined in the NCBFAA White Papers,” Coppersmith emphasized. “It is time for our industry to support that development.” Involve Thyself NCBFAA particularly emphasizes that the sooner firms become involved in ACE processing the more competitive advantages they will enjoy. For one, CBP has recently announced that the new “simplified entry release” functionality will only be available to ACE filers. ACE also provides better data integrity for ACE reports for both customs brokers and their customers. Meanwhile, NCBFAA emphasizes that additional broker live testing is critical to fully debug the ACE functionality that customs brokers will be using in their business, particularly when multi-modal cargo release becomes functional next year. “Experiment by choosing a single client for filing entries in ACE,” he recommended. “The resulting increase in utilization and experience will allow members to make meaningful sugg