The NCBFAA said it has been repeatedly assured by CBP that customs brokers would have a minimum of 30 days to test the new CF 5106 in their systems.
The association also is concerned about the “hard cutoff” between use of the old CF 5106 and the new one in CBP’s Automated Commercial Environment (ACE).
“NCBFAA, with the support of the software vendor community, requests a soft transition to the new 5106 if at all possible,” Magnus said. “If CBP is unable to provide this soft transition, then we need a more workable solution for a seamless transition from the old form to the new. A two-day gap in total functionality from end of business March 15 until the evening of March 17 or early March 18, as stated on a CBP call, will create difficulties for brokers processing cargo release in a 24/7 environment.”
The NCBFAA also noted a lack of policy documents from the agency regarding the shift to the new CF 5106. Without that, Magnus said the changeover will be “extremely difficult to manage for the brokerage community.”
Tom Gould, chairman of the Trade Support Network’s Trade Leadership Council, backed the NCBFAA concerns. “The lack of testing and training for the trade community is of great concern to the TSN,” he stated in a letter to CBP.