(For 3-177 imports & exports, 3461 imports, PPQ-505 imports, and others)

For any shipment to be cleared it must have a unique 3 character (alphabetic, numeric, or alphanumeric) Entry Filer Code as assigned by CBP to all licensed brokers or importers/exporters. This code is then always used as the first three characters of a special 11 digit number which must be computed according to an extremely complex formula for each shipment. CBP will assign this Entry Filer Code to professional brokers and large volume importers, but unfortunately for most small businesses the “large volume” threshold is defined as at least 15 shipments per month with a minimum annual value of $1,000,000.00! The only exception for smaller entities is if they already own a special Automated Broker Interface (ABI) software program used in electronic (internet) filings, one not available directly from Customs but through independent vendors and at a cost of approximately $50,000.00.

For smaller businesses that still prefer to do their own Customs clearance paperwork without hiring a broker or buying the ABI software, an alternate procedure for getting a Customs-issued Entry Filer Code number is (supposedly) available (see the above link):

Title 19: Customs Duties
    Subpart A—Entry Documentation

      § 142.3a Entry numbers.
         (e) Alternative procedure. If an importer does not have an assigned entry filer code, or if the          Assistant Commissioner, Office of International Trade, or his designee, in accordance with          paragraph (d) of this section refuses to allow use of an assigned entry filer code, the importer or          broker shall obtain forms with a CBP assigned pre-printed machine readable entry number with a          computed check digit. These forms will be available for sale by CBP and must be obtained and          used before the merchandise may be released from CBP custody.

Although this “alternative procedure” is technically one that can be used to get single-shipment entry filer code numbers, in actual practice very few CBP agents or employees are even aware that it exists. Normally these are issued for one-time-only use, such as when a shipment has arrived at the port, or is brought in by a traveler, and needs to be cleared quickly. As long as the item is otherwise legally admissible a number can be purchased and issued on the spot to help in immediately clearing it through Customs. Multiple use is discouraged but not actually prohibited, but CBP is not at all friendly toward the idea of individuals or small businesses using it to repeatedly clear shipments.

According to a Customs ABI Client Representative we spoke to in Washington, DC, if it’s discovered that this rarely used courtesy service is being “abused” for regular commercial shipments the agency will take steps to have the regulations amended to end that practice.

For anyone who cares to try, you must first locate your shipment’s port of entry, then call that port’s Broker Permit and License Administration and ask to purchase “entry forms with a CBP-assigned pre-printed machine readable entry number and computed check digit”. Request that a filer code be issued, and that it “be cleared with headquarters”. If refused, which is probable since most agents aren’t familiar with issuing filer codes, ask to speak with the “BMO” (Broker Management Officer) and repeat the request. Good luck!

ANOTHER OPTION: In order to file your own paperwork and bypass paying for brokerage services, for a nominal fee it’s possible to file electronically through vendors who have already bought ABI software and possess a CBP-issued Entry Filer Code number of their own. This is supposedly cheaper than using a broker, and there’s a list of these vendors on the CBP Automated Systems Home Page; click on the link for Automated Broker Interface (ABI) and begin shopping for a vendor.

This ABI Software Vendors List and introductory letter opens as a Word document. Keep in mind that using a vendor’s ABI software program means that you will not be in direct contact with CBP if or when issues arise. For dealing with CBP directly, you would need to have your own ABI software, or at least your own CBP-issued Entry Filer Code Number. Otherwise, it’s back to just using a standard brokerage service.

All vendors on the list have passed stringent tests to be approved but some are better or cheaper than others, so contact a number of them and ask questions. Those vendors with the most options available will also be the most expensive, so select one who has only the features your business really needs.

Since the newest CBP system for handling entry summaries is “ACE” and it’s being phased in to be mandatory within the next year or two, choose a vendor who already has this program (or ask if they will be adding it soon). It would be easier to start with ACE than to learn an older system and then be forced to switch and relearn later. Also, Make sure a vendor has the “ISF” (Importer Security Filing) feature.

Woe unto them who decree unrighteous decrees, and who write grievousness which they have prescribed… Isaiah 10:1

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