CSMS #25000123 - ACE Deployment for Enhanced Entry Summary Processing

U.S. Customs and Border Protection will deploy new ACE functionality for enhanced entry summary processing on January 15, 2025. This deployment affects all importers and brokers using the Automated Commercial Environment (ACE) system.

Scope of the WRO

The order covers:

• Polysilicon materials from specific regions
• Solar cells and modules containing affected materials
• Downstream products incorporating these components

Compliance Requirements

Importers must now provide:

• Complete supply chain documentation tracing materials to their source
• Certificates from suppliers confirming no forced labor involvement
• Third-party audit reports for high-risk suppliers
• Detailed production records for finished goods

Documentation Best Practices

To ensure smooth customs clearance:

1. Map your entire supply chain down to raw material suppliers
2. Obtain affidavits from all suppliers in the chain
3. Implement supplier codes of conduct with audit rights
4. Maintain detailed records of all sourcing decisions
5. Consider alternative sourcing from low-risk regions

CBP Detention Process

If your shipment is detained:

• You have 3 months to provide documentation proving admissibility
• CBP will review submitted evidence within 30 days
• Insufficient documentation may result in exclusion and re-export
• Pattern of violations could lead to penalties

Industry Impact

This WRO affects an estimated 40% of solar imports, potentially disrupting renewable energy projects across the United States. Industry associations are working with CBP to clarify requirements and establish approved supplier lists.

Alternative Compliance Strategies

Companies are exploring several approaches:

• Shifting to suppliers with verified ethical labor practices
• Investing in supply chain traceability technology
• Participating in industry-wide certification programs
• Developing domestic supply alternatives

Trade-IQ specializes in forced labor compliance and can help you develop robust supply chain documentation, prepare CBP admissibility packages, and identify compliant sourcing alternatives. Don't let this WRO disrupt your business - contact us today.