The United States’ Single Window:

Implementation Priorities for 2015 (4 of 4)

Executive Order 13659 established a deadline of December 2016 for completion of the United States’ Single Window, called the International Trade Data System (ITDS). Interestingly, some of the major topics of dialogue over the last year have focused on developing a common understanding of what “completion” by the December 2016 deadline actually means within the U.S. Government’s longer-term program of customs and trade modernization activities. Looking forward to transforming border management, DHS and other agencies will focus immediate work in 2015 on developing these issues by finalizing a common U.S. Government strategic vision, and prioritizing key implementation activities accordingly. This strategic vision will ensure that all stakeholders, both private and public, have common expectations and can develop plans, metrics, and other measures accordingly. The strategic vision will also guide increased engagement with industry partners willing to participate in the development and early piloting of the system.

A Strategic Vision for the Single Window

The Executive Order states that, by December 2016 relevant government agencies “shall have the capabilities, agreements, and other requirements in place to utilize” the Single Window “as the primary means of receiving from users the standard set of data and other relevant documentation required for the release of imported cargo and the clearance of cargo for export.” However, as with most things, the devil is truly in the details. Discussion continues about how DHS and other agencies can deliver not only a functional Single Window by December 2016, but support for the full range of activities between now and then to ensure that the electronic system is fully used by businesses as the primary means to process imports and exports.

DHS is committed to providing the necessary technical functionality as part of the ongoing development of the Automated Commercial Environment. Additionally, recognizing that technical enhancements will only get us so far, DHS is working to identify operational inefficiencies or policy inconsistencies among federal agencies that, if resolved, could augment Single Window capabilities and drastically improve the import and export process. As discussed in earlier posts on this topic, DHS will judge successful implementation of the Executive Order by two equally important measures: first, the improved enforcement of our nation’s laws at the border; and second, the extent to which we facilitate trade——meaning more efficient and more cost effective to import and export goods across our borders.

One of the U.S. Government’s first tasks for 2015 is to finalize an overarching strategic vision for the national Single Window project. This strategic vision will distinguish public and private experiences and capabilities today with the vision for 2016 and beyond. While Executive Order 13659 established helpful parameters, it is important to further define what a “successful” Single Window will look like and enable once fully delivered by December 2016 and as it develops in the years that follow. While the U.S. Government as a whole has not finalized all aspects of the strategic vision for this project, DHS is committed to supporting a Single Window system and associated customs modernization program that will result in the delivery of a simplified and more cost-efficient process for imports and exports. Specifically, by December 2016 DHS envisions a Single Window system able to:

• Provide for the electronic submission, receipt, and exchange of a single minimum set of data needed to review and release goods;
• Support the exchange of supplemental, post-release information;
• Reduce the amount of time to communicate back to trade where there is an issue with a shipment by automatically recognizing inaccurate or incomplete data submissions and notifying trade accordingly;
• Allow the Federal Government to make decisions regarding disposition of shipments faster and more accurately than today;
• Provide for unified, coordinated messaging to industry stakeholders regarding the status of a shipment (for example, messaging could provide industry with information on whether a shipment has been released or held at the border and, if held, provide additional information on the reason and agency responsible);
• Enable expedited cargo movement across the border for trusted traders due to demonstrated strong supply chain and trade compliance internal controls,
• Be well positioned for future interoperability with other national or regional Single Window systems.

Operational Testing

But, as has been made clear to us by engaged industry partners and advisory committees, we cannot simply flip a switch on December 2016 and expect miracles. Instead, we must work in close collaboration with industry partners to build an “on ramp” over the next two years. An ideal “on ramp” would allow both businesses and agencies to develop the necessary capabilities, conduct operational tests in real-world environments, and then incrementally ratchet-up utilization of the system while addressing the inevitable technical glitches and operational complications without disrupting shipments for pilot participants.

The Environmental Protection Agency (EPA) and the Food Safety and Inspection Service (FSIS) within the Department of Agriculture have initiated separatesmall-scale pilots that allow pre-identified traders to submit electronic data to meet specific EPA requirements for ozone-depleting substances and vehicle and engine parts and FSIS requirements for certain meat, poultry, and egg products. The initial stages of these pilots have proven successful and underscore the importance of early and sustained communication among U.S. Government agencies and between agencies and industry stakeholders.

In DHS’ perspective, the next natural step is to develop opportunities for larger pilots that involve multiple agencies, a range of different commodities, and major industry partners. The “cross-agency” pilots would, first, promote the processing of an ever-increasing volume of trade through the Single Window by prioritizing engagement with businesses in key industry sector clusters; and second, test a priority set of agency-to-agency operational enhancements (such as coordinated targeting and unified messaging of holds and releases). DHS and other agencies are finalizing a tactical plan for Single Window pilot activities, to include target metrics and milestones and key stakeholders. We look forward to sharing, discussing, and as necessary refining the details of the plan with interested parties very early next year.

Effective management of such a complex, multifaceted project promises to be challenging. Industry experts have expressed concerns with the uneven pace of different U.S. Government agencies’ transition to electronic and automated processes and have cautioned that the diversity of current risk management cultures and inspection processes may complicate efforts to streamline operations at the border. On their part, agencies express concern with attracting early business adopters willing to undertake the system updates and software conversions necessary for pilots. Managing these challenges will require active and sustained engagement from agency and company/trade association leadership and from the operational, legal, policy, and technical experts within those organizations. Additionally, DHS recognizes the value of business/management expertise and is exploring options to leverage that experience further through existing “loaned executive” programs or other innovative partnerships. We have heard from industry advisory committees and learned through our own experience that these arrangements can be of immense value to both sides.

Conclusion

As DHS and other agencies move into 2015, and another step closer to the December 2016 deadline for completion of the United States’ Single Window, we remain committed to working in close collaboration with all relevant stakeholders. I would to thank the industry advisory committees and other experts that have provided critical insights to-date and look forward to working with them and others that may have interests going forward. Thank you for your time and interest and please feel free to contact me with questions, comments, or good ideas!