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SAP GTS - US Reexport Controls

Introduction: The U.S Department of Commerce regulates exports and re-exports of "dual-use" items through EAR (Export Administrative Regulations). If any controlled product is of U.S origin or in anyway connected with U.S then even if it's shipped anywhere from outside the U.S to any other countries, it should be compliant with EAR and require a license from the U.S BIS (Bureau of Industry and Security). When a foreign-based company imports products or components from the U.S and uses them in its production, and then exports the produced materials to another country, the process is known as U.S. Re-export and is subject to U.S. regulations.  Firstly, we need to determine if any foreign-produced materials that contains the U.S origin components are subject to EAR or exempted based on the de-minimis exception. Here the ultimate destination countries are classified as "Non-Critical / Friendly Countries" and...

US AES Filing using SAP GTS


Introduction to US AES Filing:

  • Automated Export System (AES) is a proven technology/system to file the export transactions through online/digital mode.
  • Before AES, US export filing was done through paper which will be time consuming and error prone.
  • AES was implemented in phases around different US ports. Phase 1 was started in 1995 with five vessel ports and later in 1996 expanded to all other ports based on the positive outcome of Phase 1. In 1997 AES was expanded to receive the EEI for all other modes of transport like air / land.
  • The Automated Commercial Environment (ACE) AESDirect is the online web-portal for submitting the EEI to the US AES system.
  • SAP Labs is one of the authorized software vendor who is certified to submit the transactions to US CBP electronically. There are many well known companies (like Oracle, HPE, etc..) who are authorized to communicate to US CBP systems electronically.
  • Required shipment data / Commodity EEI (Electronic Export Information) can be transferred to the US CBP – AES system through an EDI (Electronic Data Interchange)
  • Shipment information that are required to be shared with the US Customs can be checked in SAP GTS through the incompletion checks and the mandatory field details can be transmitted electronically to the US AES system.
  • Any exporter (USPPI) / forwarding agent / Broker / Customer nominated forwarding agent (FPPI/Routed export) can do the AES filing with the US customs.
  • If the shared shipment details are correct and meets the filing requirement, then the filer will receive the 14 digit ITN (Internal Transaction Number) which is the confirmation for the shipment acceptance and added in the US AES system.
  • If any issues in the data, then an error response message with an error code will be sent to the SAP GTS system. ACE Appendix A from the CBP portal can be used to interpret the error message and resolve it.
  • Automated Export System Trade Interface Requirements (AESTIR) provides the Customs Proprietary and ANSI X. 12 record formats for transmitting commodity information and transportation export data to the US AES System.
  • US CBP AESTIR Appendices from A to Z provides the necessary information related to US AES filing. It can be found here in this link - https://www.cbp.gov/trade/aes/aestir/appendices
US AES Exemption:

  • AES exemption is a scenario where the shipment details are not required to be shared with the US Customs to receive an ITN/confirmation message.
  • In such scenarios we can print the relevant exemption codes in the customs forms like Shipper letter of Instructions (SLI)
  • Exemption code format is “NO EEI” (No Electronic Export Information) & then the code number.
  • Most common exemption codes - NOEEI 30.36 & NOEEI 30.37A.
  • NOEEI 30.36 (Canada based) – Shipments Destined to Canada with C33(NLR) license type are not required to be filed with the US Customs.
  • NOEEI 30.37A(Value based) – Shipment value less than USD 2500 with C33(NLR) license type are not required to be filed with the US Customs.
  • Value based Exemption is based on the item aggregation concept. Item Aggregation helps to reduce the number of reported items through aggregation. Items will be aggregated based on same HTS, Same ECCN, Same License type, Same Country of Origin-Domestic (D) / Foreign/NON-US (F), Dangerous Goods Indicator, Same Commercial description & Same Ship to Party at the item level.
  • SAP has provided a standard item aggregation schema to address this concept.
  • Prior to SAP GTS 11.0-SP19, the exemption logic was address through customized development in the Idoc Badi. In SP19, SAP has introduced the exemption codes at the item level and this functionality is standard for US AES filing.
  • However, we can still go for any customized developments for Routed export transaction exemptions.

Required Fields for US AES Customs Filing:

Most of the below fields can be transferred from SAP ECC/S4 documents to SAP GTS customs export declaration. If required then we can retrieve the available fields through developments. Also we can default the required values directly in SAP GTS through Defaulting data option.

  1. Company code with address & USPPI/EIN - FTO BP with the USPPI/EIN to be maintained.
  2. Partner function types - Declarant (CUSANM), Consignor (CUSVER), Ultimate Consignee (CUSEND),  Forwarding agent / Carrier, CUSFRW (with SCAC/IATA Code), Data transmission provider / Transfer Service (CUSDDL), Decentralized / Peripheral / Local communication partner (CUSDCC), Message Sender (CUSMES), Representative (CUSSTL). Separate Partner function type can be maintained for the forwarding agent to denote the Routed export transaction (Optional) - To have the routed export transaction to be exempted
  3. Incoterms
  4. Mode of Transport & Identifier - As per ACE Appendix T
  5. Dangerous Goods indicator for DG 
  6. Pricing details - Value of goods & Statistical value
  7. Schedule B Commodity codes - Products to be classified and supplementary units to be maintained wherever required. If unit of conversion is maintained then the supplementary units will be automatically updated.
  8. Exchange Rate types - Value to be in USD. Exchange rates can also be maintained in SAP ECC and transferred to SAP GTS through standard program RFALEX00 through Idocs.
  9. Ultimate Consignee type - One out of 4 entries to be maintained. Direct Consumer (D) / Government Entity (G) / Reseller (R) / Other-Unknown (O)
  10. Related Party Indicator / Affiliation - By default it will be blank which is non related transactions. But for intercompany transaction if the seller and the buyer are related then the value should be updated accordingly in the header-invoice tab.
  11. Office of departure - CUSAZS Partner function. Customs office of departure with the office number to be maintained
  12. Transportation documents - Bill of lading (BOL)  / Air waybill  (AWB)- HDOC category to be maintained with BOL number for Ocean shipments. Optional for air / truck shipments.
  13. License details - License type and ECCN details - AESTIR Appendix F - License and License Exemption Type Codes can be referred for the license requirement details. If compliance legal control is activated in SAP GTS, then the license details can be transferred from compliance document to the customs export declaration. If the product is listed under ITAR, then the product should be classified with USML and appropriate license types (for ex: S00 for ITAR exemptions, S05/DSP-5 for Permanent Exports) with Agreements (TAA/MAA) should be declared. All other required data elements for ITAR regulation should be declared with the US Customs. More details on ITAR vs. EAR requirements in my other blog.
  14. Commercial description - It should be based on the Tariff description. So that the item aggregation would work. If commercial description gets copied from the product description then the aggregation logic would not work. Commercial descriptions can be maintained as mass update by retrieving the commercial description text from the Descartes provided Tariff file.
  15. Customs Status The code indicating whether the shipment is being transported under bond, and if so, the type of withdrawal. Default value can be  “70 – If “Merchandise NOT Shipped In Bond”.
  16. Declaration /  Entry TypeDefault value can be “2” – “AES Option 2: Predeparture. Full pre-depart. shipment filing”. Option 1: Post-departure and Advanced Export Information (AEI) filing is only available with approved USSPPI IDs and for EEI that meet the requirements for post-departure (AEI) filing.
  17. Range Of GoodsDefault value can be “OS – “AES: All Other Exports”. Select the code that identifies the type or condition of the export transaction being made. (For ex: For Carnet Shipments  we can choose “CR”)
  18. Country of Origin - This will be transferred automatically from invoice to GTS declaration, if its maintained.
  19. Date of export - It will be the declaration date as per the entry type.
  20. Packaging Data and Container number - Packaging details will be transferred automatically from SAP ECC-Packaging to SAP GTS - Item level packaging, if the standard packaging process with the handling unit is followed in SAP ECC and packaging types are assigned in SAP GTS. Container number can be transferred through development in the billing-SD0C Badi.
Steps in AES filing:
  1. Execute the M0410 message to transmit the shipment information to US Customs through Seeburger/any middleware in form of Idocs.
  2. If the filing is successful then we will receive the shipment acceptance with ITN number through "I1560 - Commodity Shipment Filing Response (US)".
  3. If any error response then resolve the error and retransmit the error message. Error responses can be interpreted through Appendix A.
  4. Now SAP has also introduced DIS message for transmitting the required documents to US customs through digital mode.
  5. In earlier SAP version M0410 can be executed for any change / cancellation of the customs declarations after receiving the ITN.
  6. Now we have separate messages "M0412 - For change of export declaration" and "M0413 - For Reversal of the export declaration.
  7. SAP has also provided a correction option for US export declaration, where the same customs declaration and ITN can be used for any shipment modification. So that the customs declaration is not required to be cancelled and created through a new invoice. We can just create a new invoice in SAP ECC/S4 to have the customs declaration updated with the same ITN.
Configs related to US AES:
  • Most of the required configurations for the customs legal regulation "ACE" will be pre-delivered by SAP as a standard in the system. However, we can still check the system to make sure the required configurations are maintained. 
  • Maintain the Seeburger/middleware port in WE21/WEDI transaction for transmitting/receiving the idocs.
  • Maintain the Partner profiles for Seeburger/middleware in WE20/WEDI transaction with outbound parameters as "/SAPSLL/CUS_EXP" and inbound parameters as "/SAPSLL/CUS_INBOUND".
  • If outbound parameters are not maintained then while executing the message we see the processing error message as "EDI: Partner profile not available. No partner found for logical message /SAPSLL/CUS_EXP. Message processing terminated - /SAPSLL/CUS_EXP"
  • Similarly, If inbound parameters are not maintained then the inbound idocs would be stuck and won't be posted in the customs declaration.
  • To test the AES declaration in simulation, create the ports & Partner profiles as Simulation. Then the customs declaration can be tested using the transaction "/SAPSLL/IDOC_SIM".
  • We will see on how to create a new customs declaration with all the required steps in the General Settings & Customs Management in other blog.
Solution for some of the common AES Incompletion errors:
  • Number <XXX> is invalid as per the definitive date - HTS / Schedule B number is expired
  • Either the HTS or the Schedule B number has to be maintained - Maintain atleast HTS / Sch B number
  • Representative (Person) - Customs Agent does not exist - Maintain the Representative (CUSSTL) Partner function
  • Ult. Consignee Type does not exist - Maintain the Ultimate consignee type
  • Enter a forwarding agent - Maintain the forwarding agent/carrier partner function (CUSFRW)
  • Customs number Office of Departure does not exist - Maintain the office of departure
  • ID - Means of Trnsp. (Conveyance Name/Ca does not exist) - Maintain the Carrier name in Identifier field in Means of Transport at the border
  • Enter the conversion factor for base UoM to special UoM - UOM conversion is missing in product master. Maintain the supplementary unit for the HTS at the item level.
  • License data not maintained - Maintain the license details at the item level - documents tab.

Solution for some of the common AES error responses from the US Customs:
  • Error 518: Message text: Message text: F COMMODITY DESCRIPTION INELIGIBLE - Maintain the correct commercial description and retransmit. Values like "Other" not accepted as commercial description.
  • Error 649: Message text: F QUANTITY 1 CANNOT EXCEED SHPING WGT - Maintain the correct supplementary quantity and retransmit. Supplementary unit of weight cannot be more than the net/gross weight or net weight cannot be more than the gross weight.
  • Error 170: Message text: F AIR WAYBILL FORMAT: NNN-NNNNNNNN - Maintain the correct AWB number and retransmit. The Transportation Reference Number reported for this Air shipment was not in the correct format. 
  • Error 105: - Message text: F   MODE OF TRANSPORTATION UNKNOWN - Maintain the correct mode of transport (as per Appendix T) and retransmit. MOT Code should be a 2 digit code.
  • Error 545: - Message text: F BIS LICENSE NBR UNKNOWN OR INVALID - Maintain the correct external license number and retransmit. In Production use the department license number as given by the department. In test system use the test license numbers as given by the US customs for testing. Refer Appendix F for more details on licenses.
  • Error 549: - Message text: F BIS LICENSE # NOT VALID FOR LICENSE CODE - Maintain the correct external license number and retransmit. In Production use the department license number as given by the department. In test system use the test license numbers as given by the US customs for testing. Refer Appendix F for more details on licenses.
  • Appendix A can be referred for interpreting and resolving the AES errors based on the error codes.

For any queries/suggestions/corrections please drop a message. Happy Learning...                         

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