More Discussion Needed in Move Toward Rulings Updates, COAC, CBP Agree
More work is needed between CBP and the Commercial Customs Operations Advisory Committee (COAC) in moving toward an update to the agency's approach to rulings, said Brenda Smith, executive assistant commissioner with the Office of International Trade, at the March 1 COAC meeting. Smith sounded appreciative of the ideas from the COAC Rulings and Decisions Improvement Working Group, while also somewhat skeptical, given potential costs involved. "I would really welcome a conversation where I get to ask a lot of questions about your recommendations." Among the recommended improvements are an expiration date for rulings hosted on the Customs Rulings Online Search System (CROSS), and automated processing and dissemination of rulings requests and decisions (see 1702270016).
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The suggestions involve a lot of changes and "given the environment and the focus on prioritization," it's worth considering that "the investments required are significant," she said. CBP could use some further insight on what would be the "biggest bang for our buck," she said. "This, obviously, is an area that we need to focus on, so let's see how we can do it, as well as what changes we can do from a process perspective as opposed to throw a lot of money at it." Some of the recommendations aren't new ideas for the agency, while others are "fresh," she said.
There's consensus that more work will be necessary and the rulings working group will continue to exist within COAC, said Lenny Feldman, chairman of the Trade Modernization Subcommittee. COAC needs to look at the "end-to-end" to figure out how the recommendations relate to other pieces involved, he said. "I think we feel the same way, that we would like to engage in that high-level -- strategic, if you will -- workflow discussion because this office is so critical to CBP and I think it's even going to become more so."
Some of the recommendations already align with ideas discussed within the CBP Office of Regulations and Rulings, Executive Director Alice Kipel said. "So it's really great to have validation and support from our stakeholders," she said. "We're very glad to know the working group is going to continue because there's a lot here that we need to digest and look at how we can go forward together on a path to improve the workflow for everybody's sake."