CBMA Procedure Changes for 2021

Yesterday, the CBP issued CSMS #45315560 detailing the new procedures and requirements for claiming the CBMA rate in 2021. As the overall process remains the same there are a few changes with respect to the submission of documents. All three CBMA documents, Assignment Letter, Controlled Group Spreadsheet and CBMA Spreadsheet, will still need to be procured and maintained prior to taking the lower CBMA rate. These documents will NOT need to be submitted to the Documentation Imaging System (DIS) when claiming at time of entry or when filing a post summary correction (PSC). There are a few situations when the documents will need to be provided to CBP:

• CBP requests supporting documents via CBP Form 28, documents will need to be uploaded to DIS and linked to the respective entry number
• If a “DOCS Required” message appears in the ACE Portal when filing a CBMA claim at time of entry or via PSC, the documents will need to be uploaded to DIS at time of filing and linked to the respective entry number
• If claiming the CBMA rate via Protest all documents must be uploaded in the ACE protest module NOT DIS

Even though the documents are no longer required to be uploaded to DIS you must still have them on file as they can be requested at any time. As a reminder, below are the required documents needed to properly claim the lower CBMA rate:

• CBP156 – Supplier Assignment Letter – this must be received and signed by the supplier before claiming the CBMA rate
• CBP154 – Controlled Group Spreadsheet – a new 2021 spreadsheet must be received even if no changes were made since the 2020 spreadsheet
• CBP155 – CBMA Spreadsheet – this will still need to be prepared and maintained with each 2021 claim

Importers should still continue the same process for claiming the CBMA rate as they have in the past to ensure no over claims or issues should documents be requested by CBP. CBP stated in the CSMS that revisions to the procedures may be issued later in 2021. WSSA will send out updates when/if the CSMS is published. For now, please start procuring your 2021 assignment letters from your suppliers.

Please reach out with any questions on these new guidelines. Wishing everyone a Happy New Year!