What is a Post Summary Correction (PSC)? And why would you request one?
In Customs and Border Protection’s (CBP) words: “Submission of a PSC is the sole method for trade to electronically correct entry summaries prior to liquidation.”
This means that a PSC allows the importing party to modify their entries electronically, if an error is identified post submission. CBP considers these corrections as the importer’s certification that the data is correct — placing responsibility on the filer to be accurate and truthful.
This regulatory framework certainly benefits importers, as these corrections can be submitted quickly and easily with ACE.
The Automated Commercial Environment (ACE), is a CBP platform built to facilitate trade processes and enhance securities.
Requirements for filing a PSC: A Checklist
Below, you will find a quick checklist of “Dos and Don’ts” — things to look out for before filing a Post Summary Correction.
The initial entry summary for the goods must…
- Be in accepted status
- Be in CBP’s control
- Be paid in full (note: it can take up to 45 days for CBP to receive payment!)
Cannot…
- Be under additional CBP review
- Can’t be liquidated
Time frame on submitting a PSC
In 2017, CBP extended the deadline for filing these corrections. Now, they must be filed within 300 days (extending from the previous 270 days) from the date of entry into the U.S. Or alternatively, they can be filed 15 days before the liquidation date (from 20 days) — whichever one is earlier.
Are there any exclusions to what can be corrected in a PSC?
The PSC program is definitely very flexible, but there are some data elements that cannot be changed with a PSC. Take note of these elements, so that you can ensure factual and accurate submissions prior to submission of the initial documents!
Excluded data elements include…
- Port of entry
- Importer of record
- Payment type
- Live entry indicator
- Statement month
- Location of goods
- Cargo release certification (DOT, FDA, and PGA)
- Statement client branch identifier
- Consolidated summary
- Any release details, like entry filer code, or entry number
Other restrictions to take note of:
AD/CVD entry type 04 can’t be changed to another type. (recommended reading: What is Anti-Dumping Duty and Countervailing Duty?)
Entry summary cannot be flagged or unflagged for reconciliation.
Parties eligible for filing a PSC (the “PSC filer”)
Some notes of importance from CBP’s Guide to Post Summary Corrections:
- An authorized ACE entry summary filer can submit a PSC if authorized by the importer
- If the PSC is filed by someone that isn’t the entry summary filer, ownership of this entry moves to this filer
- The PSC filer is the only party that will be able to view the entry summary that was corrected
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Streamlining the process of submitting documentation for entry is largely in part to the ACE platform’s technology, where filings can be unified all in one platform.
This technology not only made it easier for importers to have their goods cleared in a timely manner, but also make corrections to the submitted documentation if an error was identified. However, close attention must be paid to all the possible exemptions from the PSC, to ensure that particular care is put into the truthful filing of those data elements.
Additionally, we recommend that the timeframes are closely followed, in order to make sure that any corrections are submitted in a timely fashion.
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Partnering up with a customs broker can help importing businesses keep a close eye on the details, so that the “burden” of compliance and accuracy is shared. Ultimately, this saves businesses capital — in duties and fines in the event of a misstep. To learn more about what a partnership with a broker could look like for you, click here.
