U.S. Importers Required to Use Post-Entry Amendment Instead of Supplemental Information Letters to Amend Customs Entries
By Laura Martino*
U.S. Customs and Border Protection (CBP) announced in today's Federal Register that it is terminating the agency's long-standing Supplementary Information Letter (SIL) program for making post-entry amendment to customs entries on September 20, 2007. After that date, importers or customs brokers seeking to amend entry summaries prior to liquidation must do so by submitting a Post-Entry Amendment (PEA) to CBP.
In addition to extending the PEA test procedure until August 21, 2008 (the "test" procedure was originally announced in late 2000 and has been extended on several occasions), CBP has made other changes to the PEA process. Effective immediately, an importer or broker filing a single PEA must submit the PEA at least 20 days prior to the scheduled liquidation date of each entry summary covered in the PEA letter (liquidation normally occurs 314 days after the entry date). Single PEAs submitted untimely will be rejected by CBP. Previously, PEAs were required to be filed promptly after discovery of the error and prior to liquidation of the one or more entry summaries covered in the PEA.
As with SILs, PEAs allows importers to continue to make amendments to already filed entry summaries prior to liquidation. However, unlike SILs, PEAs allows importers to submit to CBP a quarterly report covering the errors that occurred during the calendar quarter.
CBP anticipates that eliminating the SIL program will reduce the paperwork burden for both importers and the agency. In addition, CBP believes that the new filing deadline for single PEAs will provide the agency with the time it needs to review underpayments and overpayments of duties, taxes and fees and statistical errors prior to liquidation.
* Laura Martino is an international trade attorney in Strasburger & Price's Washington, DC office.
Labels: Customs
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