CBMA Update

As CBP/US Customs continues to refine the process to efficiently manage customs entries submitted with CBMA tax reductions, we continue to attend their webinars, speak with the CBMA team regularly and assist importers with their CBMA efforts. CBP recently announced a new update to try and ensure all supporting documents are filed timely. While the technical details listed below are primarily for your customs broker to follow, it is essential that you supply the necessary CBMA support material to ensure you do not have customs entries that were paid at the lower CBMA rate that will end up with a tax bill! Please let us know if you have any questions on the below update summary.

On April 3^rd, 2019, CBP released 2019 Procedures and Requirements for claiming CBMA tax benefits. Some important changes/updates to note are summarized below:

• CBMA Spreadsheets, Controlled Group Spreadsheets and Assignment Certifications must be uploaded to DIS (document imaging system) by the 15^th of the following month for all prior month entries where CBMA rates were claimed. For example, documents for April entries where the CBMA rate was claimed must be submitted by May 15^th. CBMA spreadsheets should be batched by month listing entries where the CBMA rate was claimed, with the earliest entry first. Thus, only ONE CBMA spreadsheet is needed for April claims.
• Importers/Brokers have until May 15^th to upload the 2019 assignment certifications, controlled group spreadsheets and CBMA spreadsheets for the entries currently taking the tax credits from January 1^st to date. CBP has confirmed that any entry that does not have the assignment, controlled group and CBMA spreadsheets for 2019, they will liquidate the entry, issue a new TAX BILL for the increase and you will be expected to POST SUMMARY CORRECT or protest with the documents required. 
• Assignment Certifications must be separated by alcohol type. If you have a supplier for both wine and spirits, they must issue a letter for wine and a letter for spirits. Any consolidated letters uploaded prior to April 4, 2019, will be "grandfathered" in but letters uploaded April 4, 2019, on must be separated.
• The Controlled Group Spreadsheet naming convention now needs to include the year: CBP154-[Controlled_Group_Name]_[Calendar Year]_Controlled_Group_Spreadsheet.xlsx, spreadsheets uploaded prior to April 4, 2019, without the year included in the naming convention will be "grandfathered" in but all uploads April 4, 2019, on must include the year in the naming convention.

Customs is working in chronological order on all entries.  For post summary correction and protest claims, we have heard confirmation that refund checks are being processed. As always, if you have any questions or concerns, please feel free to contact us.