Entry summary rejected: the two-day clock and how to avoid it

A reject in the queue is one of the few things on an entry writer's desk that comes with its own deadline. Before anyone asks why it happened, the first question is how long you have to put it right.

This post covers that clock, where to look up what the error means, and how to sort rejects by where they started. The last part matters most: the rejects that come from the desk can be prevented.

What a reject actually means

An entry summary is due, with estimated duties, within 10 working days after the time of entry, unless it was filed at the time of entry (19 CFR 142.12(b)). A rejected summary has not been accepted, and until it comes back in valid status it does not count toward meeting that deadline.

In practice, "rejected" covers two different events, and it helps to keep them apart:

• The transmission fails ACE's edits. Your ABI software gets fatal error messages back and nothing is accepted. CBP's own documents call this an automated rejection too, but nothing is on file, so don't count on the two-day grace period below. Work to the original 10-working-day deadline, and ask your ABI client representative if a specific case is in doubt.
• CBP rejects the summary. The summary reached CBP, and CBP sends it back with an "entry summary rejected" notification. This is the case the two-day clock below is written for. CBP's policy on when it accepts and when it rejects a summary is in its Entry Summary Acceptance and Rejection Policy directive (3550-067A, 2011).

The clock

CBP's rule, as set out in its Entry Summary Acceptance and Reject Process and the ACE Entry Summary Business Rules and Process Document, comes down to three points:

1. Generally, you have 2 working days after the day of the reject to return the entry summary to CBP in valid status, with payment if any is due.
2. If the summary was rejected before the 10th working day of the filing period, you have whatever is left of that 10-working-day period, and never less than 2 working days.
3. If it comes back late, CBP may issue a late-file liquidated damages claim.

The liquidated damages have a regulatory basis. If the entry summary isn't filed on time, the port director demands liquidated damages in the full amount of a single-entry bond. On a continuous bond, the demand is what it would have been under a single-entry bond (19 CFR 142.15). Applications to cancel go through 19 CFR part 172. If an importer repeatedly files late without justification, CBP can also require the entry summary and estimated duties at the time of entry, before the goods are released (19 CFR 142.13). For an importer that depends on quick release, that can cost more than the claim.

Payment. When a rejected summary has additional duty due, CBP's reject process says that payment can't be made by ACH, and the Business Rules document says the filer must pay by check. Check how that payment will be made before the resubmission goes out, not after.

Worked example

This is an example with invented timing, not a real entry. Count in working days, with day 10 as the last day of the filing window.

Rejected on	Resubmit by	Why
Day 3	Day 10	Rejected early, so the rest of the window is longer than 2 days
Day 9	Day 11	The rest of the window is 1 day, so the 2-day minimum applies
Day 10	Day 12	2 working days after the day of the reject

An early reject leaves room to work the problem properly; a late one doesn't. An entry writer who routinely transmits on day 9 or 10 has almost no margin left for a reject. The cheapest protection is to transmit early enough that the rest of the window, not the 2-day minimum, is what you are working against.

Check how your ABI software and your port count working days before relying on any of this. The count above is only an illustration.

Where to look up the error

A reject gives you a code. What that code means is published by CBP, not by your software vendor:

• The ACE CATAIR Error Dictionary explains the error messages returned on ACE ABI transactions.
• CBP's Error Message Dictionaries/Lists page links to the dictionaries for other ACE processes, such as statements and reconciliation.

Read the dictionary entry rather than guessing from the short message text in your filing system. The dictionary is CBP's own explanation of the condition, and it is the version to rely on if the fix is ever questioned.

Two kinds of cause

We don't have reliable data on which reject codes are most common, so this post doesn't offer a top-ten list. It is more useful to sort a reject by where the bad value came from, because that tells you who fixes it and whether it will happen again.

Data that came off a document. Value, quantity, country of origin, the manufacturer identification code, HTS-driven data such as missing partner-government-agency information. These values were read from an invoice, packing list or bill of lading and keyed into the summary. The fix is on the desk: go back to the source, find which document the value came from, and check it against the others. When the invoice and packing list disagree, that is often where it started; the pre-transmission checklist covers catching that before you transmit. If the MID is the problem, see how to build an MID code from a commercial invoice.

System or reference data. The bond, the importer of record number, a code that doesn't exist in the reference tables, a filer or port setting. These usually aren't read from the packet at all. The fix is in the client or system setup, and if it isn't corrected there, it will reject the next entry too.

For statistical data specifically, the regulations say CBP will reject a form where required statistical information is missing or clearly wrong on its face (19 CFR 141.61).

A simple habit helps: when you clear a reject, note which of the two groups it fell into. After a month you will know whether your rejects are a keying problem or a setup problem, and those have different fixes.

Reject rate is a supervision signal

Someone at a small family brokerage put it to us plainly: a broker whose automation produced a high reject rate, through a bug or through nobody overseeing it, could put their license in jeopardy. That isn't paranoia. CBP issues every reject, so it sees them too, and a steady rate of them suggests an office where entries go out without enough checking.

For a licensed customs broker, "enough checking" is a formal duty rather than a figure of speech: the broker has to exercise responsible supervision and control over the customs business it conducts (19 CFR 111.28). A reject log sorted by cause is one of the few pieces of evidence a small office already produces that shows supervision working.

After acceptance, it's a different tool

Everything above applies until the summary is accepted. Once it is accepted, fixing an error is no longer a resubmission, and the choice is between a post summary correction, a protest and a prior disclosure. Which one applies is covered in PSC, protest or prior disclosure.

The short version

• Treat a reject as a deadline first and a diagnosis second.
• 2 working days after the day of the reject, or the rest of the 10-day window if that's longer.
• Look the code up in CBP's error dictionary, not in the short message.
• Sort each reject as document data or reference data, and fix setup problems at the source.
• Transmit early enough that a reject doesn't leave you working to the 2-day minimum.

The rejects you can prevent are usually the ones where a value was keyed from the wrong document, and EntryWrite keeps the source page beside each extracted field so that check takes a glance rather than a search.