2002N-0278 - Small Entity Compliance Guides on Registration of Food Facilities and Prior Notice of Imported Food; Availability
FDA Comment Number : EC392
Submitter : Mr. Lorne McIntosh Date & Time: 04/19/2004 03:04:12
Organization : Quik X Transportation
International Industry
Category :
Issue Areas/Comments
There is going to be confusion regarding shippers providing FDA prior notification information to their customs brokers before the freight is turned over to the carrier. Brokers are insisting on submitting the entry information to the CBP via ABI at the same time that they are submitting the information to the FDA. As an LTL carrier, we are unable to set up electronic releases (PAPS) with the brokers until we have a completed inward manifest. When our loads are closed we then send the paperwork, inward manifest, and barcodes to the broker so the PAPS can be set up. The brokers are refusing the PAPS because they have already set up an entry with the CBP. Therefore we now have loads on our trailer on which there is no form of electronic release set up which negates the C-TPAT/FAST requirements. If the shipper allows us to provide the prior notification information to the broker at the same time as we send them our PAPS barcodes etc., then everything will be set up properly. The proximity of certain border points means that although the time frame has been met with the CBP it is difficult to meet the present timeframes of the FDA as the broker takes a longer time to submit both entries via ABI.