cbp-coac-customs-modernization-recommendations

Executive Summary
The Commercial Customs Operations Advisory Committee has approved seven strategic recommendations for U.S. Customs and Border Protection action following its September 2025 meeting. These recommendations address critical operational challenges in electronic data transmission, tariff administration, bonded movement processing, and address standardization. Implementation of these initiatives would significantly enhance customs processing efficiency, improve compliance accuracy, and reduce administrative burden across the trade community while supporting CBP’s modernization objectives.

CBP COAC Recommendations September 2025: Strategic Framework for Customs Modernization

(CBP COAC 2025年9月建议：海关现代化战略框架)

1 · Understanding COAC’s Role in Customs Policy Development

The Commercial Customs Operations Advisory Committee serves as a critical bridge between the trade community and U.S. Customs and Border Protection, facilitating dialogue on operational challenges and recommending policy solutions that benefit both regulatory enforcement and commercial efficiency.

COAC Framework and Authority

Advisory Committee Structure: COAC operates under the Federal Advisory Committee Act as a formal advisory body providing structured input to CBP on matters affecting commercial customs operations.

Committee Composition and Expertise: The committee comprises trade professionals representing diverse sectors of the international trade community:

Import and Export Community: Representatives from major importers, exporters, and trade associations
Customs Brokers and Forwarders: Professionals managing daily customs compliance operations
Carriers and Logistics Providers: Transportation and logistics companies navigating regulatory requirements
Technology Vendors: Providers of customs compliance software and systems
Legal and Consulting Experts: Trade attorneys and compliance consultants with specialized expertise

Recommendation Process: COAC develops recommendations through subcommittee analysis of specific operational challenges, followed by full committee deliberation and formal approval. Approved recommendations represent consensus views of the trade community on priority modernization needs.

Strategic Context for September 2025 Recommendations

Operational Environment: The September 2025 COAC recommendations reflect current challenges in customs operations shaped by several factors:

Regulatory Complexity:

Tariff Administration: Increased complexity from evolving tariff structures and trade policy changes
De Minimis Elimination: Operational adjustments following suspension of Section 321 duty-free treatment
Security Requirements: Enhanced cargo security and risk assessment mandates
Data Requirements: Expanding electronic data submission requirements across trade processes

Technology Modernization:

Digital Transformation: Ongoing migration from paper-based to electronic processing systems
System Integration: Need for seamless data exchange across CBP and trade community systems
Automation Opportunities: Potential for technology to improve efficiency and accuracy
User Experience: Focus on making complex regulatory requirements more accessible

2 · Enhanced Electronic Data Messaging for Critical Dates

COAC’s first recommendation addresses a fundamental operational challenge: ensuring stakeholders receive accurate date information essential for regulatory compliance and duty calculation.

Regulatory Date Requirements in Customs Processing

Critical Date Dependencies: Multiple regulatory and statutory requirements depend on accurate date information, affecting duty calculation, compliance deadlines, and cargo processing:

Duty Calculation Dates:

Date of Importation: Determines applicable duty rates for goods subject to time-sensitive tariff changes
Date of Entry: Establishes the regulatory framework applicable to specific transactions
Currency Conversion Dates: Determines exchange rates for foreign currency valuation
Preferential Trade Agreement Dates: Affects eligibility for reduced duty rates under trade agreements

Cargo Processing Dates:

Importer Security Filing Deadlines: Determines ISF filing requirement timelines
General Order Dates: Establishes when unclaimed goods transfer to general order status
In-Bond Transit Periods: Governs bonded movement timeframes and expiration dates
Quota Opening and Closing: Affects eligibility for tariff rate quotas and quantitative restrictions

Current System Limitations

Data Availability Challenges: Trade community members frequently encounter difficulties obtaining critical date information through existing CBP systems:

Manifest Query Limitations: Current manifest query responses often lack comprehensive date information necessary for accurate compliance management and duty calculation, requiring supplemental research and manual verification.

Cargo Release Message Gaps: Cargo release status messages may not consistently include all pertinent dates affecting post-release compliance obligations and financial settlement requirements.

Impact on Compliance: These data gaps create operational inefficiencies and compliance risks:

Duty Calculation Errors: Incorrect dates leading to duty assessment errors requiring post-entry corrections
Deadline Miscalculation: Risk of missed filing deadlines due to uncertain date information
Reconciliation Difficulties: Challenges in matching CBP records with internal systems due to date discrepancies
Resource Burden: Additional staff time required for manual date verification and correction

3 · AI-Powered Chatbot for Tariff Guidance

The second recommendation addresses the growing complexity of tariff administration and the need for accessible, accurate guidance on tariff-related questions affecting daily operations.

Tariff Administration Complexity

Evolving Tariff Landscape: The U.S. tariff system has grown increasingly complex through multiple policy developments:

Tariff Stacking Phenomena: Multiple layers of duties may apply simultaneously to specific goods:

Base Column 2 Duties: Standard most-favored-nation rates under Harmonized Tariff Schedule
Additional Duties: Supplemental duties imposed under various statutory authorities
Section 301 Tariffs: Product-specific duties targeting unfair trade practices
Section 232 Tariffs: National security-based duties on certain imports
Safeguard Measures: Temporary protective duties on surge imports

De Minimis Elimination Impact: The suspension of Section 321 duty-free treatment creates new questions for shipments previously exempt from duty payment, requiring guidance on:

Duty Assessment Methodologies: Understanding ad valorem versus specific duty approaches
Documentation Requirements: Determining necessary paperwork for low-value shipments
Alternative Entry Methods: Evaluating postal channels versus commercial entry
Compliance Obligations: Understanding record-keeping and payment requirements

Postal Channel Considerations: Changes in international mail processing requirements create questions about using postal channels for commercial shipments, including eligibility criteria and procedural requirements.

Current Information Access Challenges

Fragmented Information Sources: Trade community members currently must consult multiple sources to answer tariff questions:

Available Resources:

CBP Website: General information requiring significant navigation and interpretation
CROSS Rulings Database: Technical ruling letters addressing specific scenarios
Harmonized Tariff Schedule: Complex legal text requiring expertise to interpret
Federal Register Notices: Scattered policy announcements across multiple publications
Port-Specific Guidance: Inconsistent information from different port offices

Accessibility Barriers: These resources present challenges for users without specialized customs expertise:

Technical Language: Legal and regulatory terminology difficult for non-specialists to understand
Scattered Information: Relevant guidance distributed across multiple sources requiring extensive research
Time Investment: Significant time required to locate and interpret applicable information
Consistency Concerns: Potential for conflicting guidance from different sources or port offices

Proposed Chatbot Solution Architecture

AI-Powered Question Answering: COAC recommends CBP develop an artificial intelligence-powered chatbot to address frequently-asked questions about tariffs and related issues.

Core Functionality: The chatbot should provide accessible guidance on priority topics:

Tariff Stacking Guidance:

Applicable Duty Layers: Identification of which duty categories apply to specific goods
Calculation Methodology: Step-by-step explanation of how to calculate total duty liability
Recent Changes: Updates on new tariff impositions or modifications
Special Programs: Guidance on exclusion processes and mitigation programs

De Minimis Implementation:

Current Status: Clear explanation of de minimis suspension and its implications
Duty Assessment: Guidance on how duties are calculated for previously exempt shipments
Compliance Requirements: Explanation of new documentation and payment obligations
Transition Support: Information on adapting operations to changed requirements

Postal Channel Usage:

Eligibility Criteria: Clear definition of what can be shipped through postal channels
Procedural Requirements: Step-by-step guidance on postal entry processes
Limitation Understanding: Explanation of restrictions and prohibited uses
Alternative Options: Information on when commercial entry is required or preferable

Technical Implementation Considerations: Effective chatbot development requires several technical capabilities:

Natural Language Processing:

Question Understanding: Ability to interpret questions phrased in various ways
Context Recognition: Understanding of trade terminology and customs concepts
Multi-Turn Dialogue: Capability to ask clarifying questions and provide progressive answers
Plain Language Responses: Translation of regulatory requirements into accessible language

Knowledge Base Integration:

Authoritative Sources: Integration with official CBP guidance and regulatory texts
Regular Updates: Automated incorporation of new rulings, Federal Register notices, and policy changes
Citation Provision: References to authoritative sources supporting provided answers
Escalation Pathways: Clear routes to human experts for questions beyond chatbot capabilities

Implementation Benefits: A well-designed tariff chatbot would deliver significant value to the trade community:

Improved Access to Information:

24/7 Availability: Instant access to tariff guidance without waiting for business hours
Simplified Interface: User-friendly access to complex regulatory information
Consistent Answers: Standardized responses eliminating port-to-port variation
Time Efficiency: Immediate answers reducing research time significantly

Enhanced Compliance:

Reduced Errors: Better understanding of requirements reducing misclassification and underpayment
Proactive Guidance: Identification of requirements before transactions occur
Self-Service Resolution: Resolution of routine questions without requiring formal ruling requests
Educational Value: Improved trade community understanding of tariff requirements

4 · Electronic Permit to Transfer for Bonded Movements

The third recommendation addresses modernization of bonded movement authorization, replacing fragmented paper-based processes with comprehensive electronic systems.

Bonded Movement Framework

In-Bond Transportation Authority: U.S. customs regulations permit movement of imported goods under bond before formal entry, allowing transportation between ports or to bonded facilities for storage or processing.

Movement Categories:

Immediate Transportation (IT): Movement from port of arrival to port of entry
Transportation and Exportation (T&E): Movement through U.S. territory for export
Warehouse Withdrawal (WD): Movement from bonded warehouse to another location
Foreign Trade Zone Transfers: Movements between FTZ facilities

Current Authorization Methods: Bonded movements currently require authorization through various mechanisms depending on transportation mode and specific circumstances, creating operational complexity and inconsistency.

Existing Process Challenges

System Fragmentation: Authorization processes vary significantly across transportation modes and port locations:

Mode-Specific Variations:

Ocean Shipments: May use manifest-level authorization or container-specific permits
Air Cargo: Different procedures for consolidated versus individual shipments
Truck Movements: Varied approaches to authorizing domestic truck transport
Rail Shipments: Distinct processes for rail carrier in-bond movements

Paper-Based Components: Despite electronic systems for many functions, paper permits remain required in certain circumstances:

Manual Processing: Physical permit documents requiring preparation and handling
Documentation Transfer: Need to physically transmit permits between parties
Record Keeping: Paper filing requirements creating storage and retrieval challenges
Verification Difficulties: Challenges in confirming permit status and validity

Operational Inefficiencies: Fragmented authorization processes create multiple operational problems:

Processing Delays: Time required for manual permit issuance and distribution
Error Potential: Manual processes creating opportunities for documentation errors
Limited Visibility: Difficulty tracking permit status and movement authorization
Resource Requirements: Staff time required for manual permit management

Recommended Electronic System

Unified Electronic Permit to Transfer: COAC recommends CBP implement electronic permit to transfer functionality for all bonded movements within a port across all transportation modes.

System Characteristics: The electronic system should provide comprehensive functionality:

Universal Application:

All Transportation Modes: Consistent electronic authorization for ocean, air, truck, and rail movements
All Movement Types: Coverage of IT, T&E, WD, and FTZ transfer authorities
Port-Wide Scope: Application to all movements within port authority
Standardized Process: Uniform procedures eliminating mode-specific variations

Real-Time Authorization:

Electronic Submission: Permit requests submitted through ACE or trade community portals
Automated Processing: System validation and authorization without manual review for routine movements
Instant Confirmation: Immediate authorization response enabling prompt cargo movement
Status Tracking: Real-time visibility into permit status and movement progress

Implementation Benefits: Electronic permit to transfer would deliver significant operational improvements:

Efficiency Gains:

Faster Processing: Immediate electronic authorization eliminating manual processing delays
Reduced Errors: Automated validation catching errors before authorization
Lower Costs: Elimination of paper handling and storage expenses
Improved Visibility: Real-time status information supporting better planning and coordination

Compliance Enhancement:

Better Control: Improved tracking of bonded movements and status monitoring
Audit Trail: Complete electronic records supporting compliance verification
Reduced Risk: Automated validation reducing risk of unauthorized movements
Simplified Management: Streamlined processes making compliance easier and more reliable

5 · Elimination of Paper-Based In-Bond Processing

The fourth recommendation extends modernization efforts to eliminate remaining paper-based in-bond processes, particularly CBP Form 6043, replacing them with comprehensive electronic alternatives.

Current In-Bond Process Structure

In-Bond System Overview: In-bond procedures govern movement and handling of imported goods before formal customs clearance, including transportation between locations and storage in bonded facilities.

CBP Form 6043 Function: CBP Form 6043 serves as the paper-based in-bond cargo manifest, documenting cargo moving under bond authority and providing accountability for goods in transit.

Form Applications:

Cargo Documentation: Detailed listing of goods moving under bond
Carrier Responsibility: Evidence of carrier’s responsibility for bonded cargo
Arrival Confirmation: Documentation of cargo arrival at destination
Closeout Verification: Proof that bonded movements completed as authorized

Paper Process Limitations

Operational Challenges: Paper-based in-bond processing creates multiple operational inefficiencies:

Documentation Management:

Form Preparation: Time-consuming manual completion of paper forms
Physical Distribution: Need to physically transmit forms between parties and CBP offices
Storage Requirements: Paper document storage and retention obligations
Retrieval Difficulties: Challenges locating specific documents when needed

Processing Delays:

Manual Review: CBP review of paper forms requiring staff time and attention
Physical Transfer Time: Delays from physical document movement between locations
Closeout Processing: Manual verification of arrival and closeout documentation
Error Correction: Time-consuming process for correcting errors on paper documents

Visibility Limitations:

Status Uncertainty: Limited ability to check in-bond movement status remotely
Tracking Gaps: Difficulty monitoring cargo location and movement progress
Exception Detection: Delayed identification of problems or discrepancies
Information Sharing: Challenges providing real-time information to customers and stakeholders

Electronic Alternative Framework

Comprehensive Digital System: COAC recommends complete replacement of CBP Form 6043 and other paper-based in-bond processes with electronic alternatives providing enhanced functionality and efficiency.

Electronic System Features: The recommended system should incorporate multiple capabilities:

Digital Data Submission:

Electronic Filing: Submission of in-bond cargo information through ACE or approved systems
Structured Data: Standardized electronic data formats ensuring consistency and accuracy
Automated Validation: System validation of data completeness and accuracy before acceptance
Integration: Seamless data exchange with related customs systems and processes

Real-Time Processing:

Immediate Acceptance: Electronic acknowledgment of in-bond filings
Automated Closeout: Electronic confirmation of arrival and movement completion
Exception Handling: Automated identification of discrepancies requiring attention
Status Updates: Real-time information on in-bond movement status and location

Enhanced Visibility:

Query Capabilities: Online access to in-bond movement information and status
Tracking Integration: Connection with cargo tracking systems for complete visibility
Reporting Tools: Electronic reports on in-bond activity and performance metrics
Stakeholder Access: Secure information access for authorized parties

Implementation Advantages: Electronic in-bond processing would provide substantial benefits:

Operational Efficiency:

Faster Processing: Immediate electronic filing and acceptance versus manual paper handling
Lower Costs: Elimination of paper, printing, storage, and physical distribution expenses
Reduced Errors: Automated validation catching errors before submission acceptance
Improved Productivity: Staff time freed from manual form processing for higher-value activities

Enhanced Management:

Better Oversight: Real-time visibility enabling proactive management of bonded cargo
Compliance Improvement: Complete electronic audit trail supporting compliance verification
Risk Reduction: Automated monitoring identifying potential issues early
Customer Service: Improved information access supporting better customer service

6 · Customs Bond Amount Calculation Modernization

The fifth recommendation addresses anomalies in customs bond amount calculation rules, specifically proposing elimination of inefficient $10,000 increments for continuous bonds in certain value ranges.

Customs Bond Framework

Bonding Requirement Purpose: U.S. customs regulations require bonds to ensure payment of duties, taxes, and potential penalties, protecting government revenue while enabling cargo release before final duty determination.

Bond Types:

Single Transaction Bonds: Cover individual import transactions
Continuous Bonds: Cover all transactions by an importer during a one-year period
Activity-Specific Bonds: Secure particular activities like bonded warehouse operation or foreign trade zone use

Activity Code Structure: CBP uses activity codes to categorize different bonding requirements, with Activity Code 1 covering basic import transactions.

Current Bond Amount Calculation Rules

Continuous Bond Minimum: Activity Code 1 continuous bonds require a minimum amount of $50,000, providing baseline coverage for import activity.

Calculation Methodology: For importers whose annual duty, tax, and fee liabilities exceed the minimum coverage, bond amounts are calculated as 10% of projected annual obligations.

Rounding Rules: Current CBP guidance specifies rounding rules for calculated bond amounts, creating what COAC identifies as an inefficient structure in certain value ranges:

Current Structure:

Under $500,000 Annual Duties: $50,000 minimum bond applies
$500,000 to $1,000,000: Bond amounts increase in $10,000 increments
Over $1,000,000: Bond amounts increase in $100,000 increments

Operational Anomaly: The $10,000 increment structure for the $50,000-$100,000 range creates multiple incremental bond amounts ($60,000, $70,000, $80,000, $90,000) that add administrative complexity without meaningful benefit.

Identified Problems with Current Structure

Administrative Burden: The multiple incremental amounts create unnecessary complexity:

Calculation Complexity:

Precise Rounding: Determining exact bond amount within $10,000 increment range requires detailed calculation
Frequent Adjustments: Small changes in import activity may trigger bond amount changes
Documentation Requirements: Each bond amount change requiring paperwork and processing
Verification Challenges: Difficulty verifying appropriate bond amounts during reviews

Practical Implementation Issues:

Surety Company Complications: Multiple bond amounts complicating surety company pricing and administration
System Configuration: Trade management systems requiring configuration for multiple bond amount options
Resource Consumption: Staff time spent on calculating and verifying precise bond amounts
Minimal Risk Differentiation: Small bond amount differences providing little meaningful differentiation in risk coverage

Recommended Simplified Structure

Streamlined Rounding Rules: COAC recommends eliminating the $10,000 increments for Activity Code 1 continuous bonds, implementing a simpler two-tier structure:

Proposed Structure:

$50,000 Minimum: For importers with annual duties under $500,000
$100,000 Next Increment: For importers with annual duties between $500,000 and $1,000,000
Standard Progression: Existing $100,000 increments continue for higher duty volumes

Simplified Decision Logic: Under the recommended approach, bond amount determination becomes straightforward:

10% Calculation: Calculate 10% of projected annual duties
If under $50,000: Use $50,000 minimum
If between $50,000 and $100,000: Use $100,000
If over $100,000: Round to next $100,000 increment

Implementation Benefits: The simplified structure would provide multiple advantages:

Administrative Efficiency:

Easier Calculation: Straightforward determination of required bond amounts
Reduced Changes: Fewer bond modifications due to elimination of small increments
Simpler Verification: Clearer rules for compliance verification and audit reviews
Lower Processing Costs: Reduced administrative burden for both CBP and trade community

Maintained Risk Management:

Adequate Coverage: $100,000 coverage level sufficient for importers in affected range
Appropriate Protection: Maintains government revenue protection while simplifying administration
Risk-Based Approach: Higher-risk importers still require calculated bonds based on actual duty levels
Flexibility Preservation: Ability to require higher bonds for specific risk situations remains unchanged

7 · Address Standardization in CBP Records

The final two recommendations address address data quality, proposing standardization of physical and mailing addresses and identification of high-risk addresses frequently associated with non-physical business locations.

Address Data Importance in Customs Operations

Critical Role of Address Information: Accurate address data serves multiple essential functions in customs operations and trade enforcement:

Regulatory Functions:

Entity Identification: Distinguishing between different legal entities and establishing identity
Compliance Verification: Verifying importer legitimacy and operational reality
Risk Assessment: Evaluating import transaction risk based on location patterns
Enforcement Support: Supporting investigations and enforcement actions

Operational Uses:

Communication: Facilitating correspondence with importers and other stakeholders
Service of Process: Enabling legal service of notices and administrative documents
Examination Coordination: Coordinating physical examinations and facility visits
Verification Activities: Supporting post-entry verification and compliance audits

Current Address Data Challenges

CBP Form 5106 Process: CBP Form 5106, the Importer ID Input Record, serves as the mechanism for creating or updating name and address information in CBP systems.

Data Quality Issues: Current processes allow various address-related problems:

Physical versus Mailing Address Confusion:

Inconsistent Distinction: Lack of clear standardization between physical location and mailing addresses
Data Field Misuse: Physical address fields sometimes populated with mailing addresses or vice versa
Incomplete Information: Missing or inadequate address data in one or both address categories
Update Inconsistency: Changes to one address type not reflected in related address fields

High-Risk Address Usage: Certain address patterns create compliance and enforcement concerns:

P.O. Box Centers:

Physical Address Masking: Use of P.O. box service physical addresses as business locations
Entity Verification Difficulty: Challenges confirming actual business existence and operations
Enforcement Complications: Physical locations not accessible for verification or inspection
Risk Correlation: Documented association between certain address types and higher violation rates

Business Service Centers:

Virtual Office Addresses: Use of business center addresses without actual operational presence
Multiple Entity Overlap: Same address associated with numerous unrelated entities
Verification Challenges: Difficulty confirming which entities actually operate from location
Risk Indicators: Patterns suggesting shell companies or illicit trade structures

Recommended Address Standardization

Form 5106 Enhancement: COAC recommends CBP standardize physical and mailing addresses when processing CBP Form 5106 or its electronic filing equivalent.

Standardization Elements: The recommendation encompasses several data quality improvements:

Field Clarity:

Clear Definitions: Explicit definitions distinguishing physical location from mailing addresses
Separate Fields: Distinct data fields for physical and mailing addresses preventing confusion
Validation Rules: System validation ensuring addresses are complete, properly formatted, and distinct
Required Elements: Mandatory inclusion of both address types when different

Data Consistency:

Format Standardization: Consistent address formatting following postal standards
Update Synchronization: Coordinated update of related address fields when changes occur
Quality Checks: Automated validation of address legitimacy and formatting
Error Identification: System flags for addresses failing validation criteria

High-Risk Address Identification

Proactive Address Pattern Recognition: The second address-related recommendation proposes CBP identify physical addresses frequently associated with higher-risk situations.

Target Address Categories: CBP should develop and maintain databases of addresses commonly used inappropriately:

P.O. Box Service Locations:

Identification: Compilation of physical addresses associated with P.O. box services
Flagging System: Automated alerts when these addresses appear as business physical locations
Enhanced Scrutiny: Additional verification requirements for entities using flagged addresses
Educational Outreach: Guidance to trade community on appropriate address usage

Business Service Centers:

Address Compilation: Database of commercial mail receiving agency and virtual office addresses
Risk Assessment: Evaluation of entities using such addresses as primary business locations
Pattern Analysis: Identification of address patterns associated with compliance problems
Verification Protocols: Enhanced verification procedures for high-risk address patterns

Implementation Benefits: Enhanced address data management would provide significant value:

Risk Management Improvement:

Better Targeting: More effective identification of high-risk import transactions
Resource Efficiency: Focused enforcement attention on genuinely suspicious patterns
Fraud Detection: Improved ability to detect shell companies and fictitious importers
Pattern Recognition: Enhanced understanding of address patterns associated with violations

Operational Enhancement:

Communication Reliability: Improved ability to contact importers and other parties
Verification Efficiency: Faster, more reliable entity verification processes
Data Quality: Higher-quality data supporting better decision-making across customs operations
Compliance Support: Clearer guidance helping legitimate businesses provide appropriate information

8 · Strategic Implications for the Trade Community

COAC’s September 2025 recommendations represent a comprehensive modernization agenda with significant implications for logistics providers, customs brokers, importers, and other trade community stakeholders.

Implementation Timing and Prioritization

CBP Review and Response Process: Following COAC recommendation approval, CBP will evaluate each proposal considering operational feasibility, resource requirements, and strategic priorities.

Expected Timeline Considerations: Implementation timing will vary based on multiple factors:

Technical Complexity:

Simple Enhancements: Recommendations requiring minor system modifications may implement relatively quickly
Significant Development: Complex initiatives like chatbot development requiring substantial development time
Integration Requirements: Proposals requiring integration with multiple systems facing longer timelines
Testing Needs: New capabilities requiring extensive testing before production deployment

Resource Availability:

Budget Constraints: Implementation limited by available funding for development and deployment
Staff Capacity: Technical staff availability affecting development timelines
Priority Balancing: Competition with other CBP initiatives for resources and attention
Stakeholder Input: Time required for trade community consultation on implementation details

Preparing for Modernization Changes

Proactive Stakeholder Positioning: Trade community members should prepare for eventual implementation:

System Readiness:

Technology Evaluation: Assessing whether existing systems can accommodate enhanced CBP data elements
Integration Planning: Identifying necessary system modifications to utilize new electronic capabilities
Process Review: Evaluating current workflows to incorporate improved electronic processing
Training Preparation: Developing staff training plans for new systems and capabilities

Policy and Procedure Updates:

Documentation Review: Updating internal procedures to reflect electronic processes
Compliance Programs: Incorporating enhanced data availability into compliance monitoring
Quality Assurance: Enhancing data validation processes to leverage CBP system improvements
Risk Management: Utilizing improved visibility for better risk identification and mitigation

Strategic Positioning Opportunities

Competitive Advantages: Early adoption of enhanced capabilities can provide competitive benefits:

Operational Efficiency:

Faster Processing: Leveraging electronic systems for quicker transaction processing
Lower Costs: Reducing expenses through automation and elimination of manual processes
Improved Accuracy: Utilizing automated validation and enhanced data for better compliance
Better Visibility: Providing customers superior tracking and status information

Service Differentiation:

Technology Leadership: Demonstrating commitment to modern, efficient operations
Compliance Excellence: Leveraging enhanced systems for superior compliance performance
Customer Experience: Providing better service through improved information access and processing speed
Risk Management: Offering clients better risk mitigation through enhanced monitoring capabilities

Long-Term Modernization Trajectory

Comprehensive Digital Transformation: These recommendations reflect broader CBP commitment to digital transformation:

Vision for Electronic Processing:

Paper Elimination: Continuing migration from paper-based to fully electronic processes
Real-Time Systems: Enhanced real-time data exchange and transaction processing
Automated Intelligence: Increased use of artificial intelligence for guidance and decision support
Integrated Operations: Seamless integration across CBP systems and trade community platforms

Trade Community Adaptation: Success requires coordinated evolution across the trade ecosystem:

System Investment: Continued investment in technology enabling effective CBP system utilization
Process Innovation: Redesigning workflows to capitalize on electronic capabilities
Skill Development: Building staff capabilities to manage increasingly sophisticated systems
Collaborative Engagement: Ongoing participation in policy development through COAC and other channels

Conclusion: Embracing Customs Modernization

Recommendation Significance

Comprehensive Modernization Framework: COAC’s September 2025 recommendations address multiple dimensions of customs operations requiring enhancement, from electronic data transmission and tariff guidance to bonded movement processing and address data quality.

Stakeholder Benefits: Implementation would deliver significant value across the trade community:

Operational Efficiency: Reduced processing times and administrative burden through automation
Compliance Enhancement: Improved accuracy and simplified compliance through better systems and guidance
Cost Reduction: Lower costs from electronic processing and elimination of manual procedures
Improved Service: Better customer service through enhanced visibility and faster processing

Strategic Perspective for Logistics Providers

Opportunity Recognition: These recommendations present opportunities for forward-thinking logistics providers and customs brokers:

Technology Leadership: Early adoption of enhanced capabilities positions firms as technology leaders, attracting customers seeking sophisticated, efficient service partners.

Process Innovation: Enhanced CBP systems enable process innovations that improve service quality while reducing costs, creating sustainable competitive advantages.

Risk Management: Better data and improved monitoring capabilities support superior risk management, protecting both service providers and their clients from compliance issues.

Future Outlook

Continued Evolution: CBP’s modernization efforts will continue beyond these specific recommendations, with ongoing development of enhanced capabilities and streamlined processes.

Trade Community Role: Active engagement through COAC and other channels ensures trade community perspectives inform policy development, creating regulations that balance enforcement needs with operational efficiency.

Collaborative Success: Successful modernization requires partnership between CBP and the trade community, with both sides committed to enhancing efficiency while maintaining strong compliance and security.

The September 2025 COAC recommendations represent significant steps toward a more efficient, transparent, and effective customs operation. Logistics providers who prepare for these enhancements and position themselves to leverage new capabilities will be well-positioned for success in an increasingly sophisticated trade environment.

This analysis reflects COAC recommendations as approved in September 2025. CBP will evaluate each recommendation through its internal review process, and implementation timing and specific approaches may differ from recommendations as approved. Trade community members should monitor CBP announcements through CSMS messages, Federal Register notices, and official CBP communications for updates on implementation plans and timelines.

CBP COAC Recommendations September 2025: Strategic Modernization Priorities for U.S. Customs Operations