Mandatory Advance Electronic Information for International Mail Shipments
2021-05-13 2021-06-14 2021-05-13 2021-05-03
USCBP-2021-0009-0006 USCBP-2021-0009-0020 USCBP-2021-0009-0007 USCBP-2021-0009-0003
04:00:00 04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/USCBP-2021-0009-0006 https://api.regulations.gov/v4/comments/USCBP-2021-0009-0020 https://api.regulations.gov/v4/comments/USCBP-2021-0009-0007 https://api.regulations.gov/v4/comments/USCBP-2021-0009-0003
Anonymous Anonymous Anonymous Anonymous
Anonymous Anonymous Anonymous Anonymous
To the attention of Secretary Mayorkas:The American Consumer Institute Center for Citizen Research (ACI) would like to take the opportunity to address the Mandatory Advance Electronic Information for International Mail Shipments interim final rule (IFR) issued by the Department of Homeland Securitys U.S. Customs and Border Protection (CBP) to implement portions of the Synthetics Trafficking and Overdose Prevention Act (STOP Act; P.L. 115-271, Title VIII).  The Synthetics Trafficking and Overdose Prevention (STOP) Act was designed to help law enforcement and security agencies to identify and prevent hazardous substances, such as synthetic opioids and other dangerous items, from traveling through the U.S Postal Service (USPS) into the United States. ACI has touted the critical nature of such measures and has previously noted, The solutions created by the STOP Act will give law enforcement the tools necessary to begin stemming the intrusion of illicit items in the nations mail system. Specifically, this entails requirements on the USPS to collect and monitor advanced electronic data on shipments that enter the country. Such responsibilities would parallel the practices used by private delivery companies, which track every package and gather key data on the contents in order to assist coordination with U.S. Customs and Border Protection other federal securities entities. The STOP Act as written provides a clear schedule for accelerated levels of compliance that has allotted U.S. institutions to set their own frameworks for operational change and resource adjustments in order to meet objectives. The measures of the law are rightfully thorough in that they establish provisions for the myriad of elements of potentially exploitable delivery. The posture of the IFR as proposed would undermine this comprehensive configuration and thus jeopardize the overall purposes of the STOP Act.   In order to regain the trust of consumer communities in logistics and delivery markets, it is incumbent upon DHS to transparently detail the inflows of mail and packages and correspondingly provide data on the actions taken to assess each item, such that stakeholders and lawmakers can ascertain how exactly USPS and CPB are making good on assurances in this critical arena. The circumstances surrounding the origin of the law should remain apparent for the Department, and more broadly for the Administrations awareness. Unfortunately, for a 12-month period ending this past September, more than 87,000 Americans died of a drug overdose, surpassing the toll from any year since the opioid epidemic began in the 1990s.  The continuation of such trends heightens the concern for muting policies or laws that are actively working to prevent dangerous substances from entering our country. In a statement submitted by Robert Cintron Vice President, Logistics of United States Postal Service to the Permanent Subcommittee on Investigations of the Homeland Security and Governmental Affairs Committee, USPS was able to see the advance electronic data (AED) percentage for inbound international packages peak at 67 percent in January 2020, up from almost zero AED in the six years prior. While this is a demonstrated improvement, it is still cause for concern as the law called for an extensive grace period in the lead up to 100 percent compliance by January 1, 2021. Cintron admitted that AED progress reversed as the coronavirus pandemic affected international shipments but expressed his belief that once international mail recovers, he expects the AED will as well. While there is no accounting for the exact effect the coronavirus pandemic had on this effort, the USPS is still responsible for fulfilling its obligations.ACI further acknowledges and respects the USPS Inspector Generals role in assessing compliance, however concerns remain about the reticence of transparency and the redactions of key information that remain shielded from public review in their report.  Limiting the obfuscation in this regard, wherever feasible, and similarly elucidating the criteria through which foreign nations may be considered for any form exemptions, would represent prudent action on the part of the Department.In closing, we trust that the Department shall not be unduly influenced by the notions that enforcement of AED obligations could hypothetically prompt retaliation from foreign postal services.  Direct causation cannot be automatically assumed and such potential externalities are largely immaterial to actions dictated by the statutes of the law.  Ultimately, the STOP Act provisions must be held up to its full lifesaving potential in service to American consumers. Thank you for your consideration. Respectfully,Steve PociaskPresident/CEO American Consumer Institute1701 Pennsylvania Avenue, NW, Suite 200Washington, DC  20006ATTACHMENT: PDF includes footnotes and letterhead I dissent, 100%, and heres why. Treatment and education work, prohibition never has. This is a ridiculously convoluted, failure of a proposal. This act is supposed to stop opiodsspecifically fentanylfrom entering the country. But its not. Instead, I am now getting perfectly legal substances seized, returned to the sender, taking months to arrive, or possibly even scammed. These are supplements like piracetam, choine bitartrate, creatine, PEA (phenylethylamine),  and NAC (n-acetyl-cysteine, which literally saved my life when doctors couldnt help me at all.) I have used these items for years; they are completely legal, non-addictive, and safe. I have friends who have had clothing (not imitation clothing either, but simple things like a scarf from a grandmother), pictures, and even raw honey from Europe, be returned to the sender or just disappear. Lost to the backlog at the ISC locations, or maybe just stolen. Ill never know. This is beyond unacceptable. AED has already failed and it has only just started. Now, there are countries that refuse to ship anything to the United States, and the ones that still do, dont guarantee delivery or provide tracking information, so internet scamming has exploded. The USPS has been pushed past the breaking point. The backlog is insane and unacceptable. The USPS is directly affected to the point that they cant even guarantee next day domestic delivery anymore. Unacceptable. Need I mention the cost of running this program? You all know the figures. Theyre ridiculous. Returning parcels to other countries at the expense of the people is not what our taxes are meant for. Especially when we have an exploding homeless population across the country, a failing infrastructure, a police force in desperate need of new and more thorough training so people trust them again and dont fear them, as well as a broken healthcare system that has enslaved us. No longer can we rely on saving money by importing our prescribed medications, but we have to pay the outrageous prices of big pharma so we can stay alive and healthy. Were now slaves to the FDA, discretionary CBP tactics, and big pharmaceutical companies. We have lost yet another freedom. As for people importing the research chemicals that have reportedly intoxicating effects; this is just another form of prohibition, and prohibition has been proven time after time to not work. It only makes criminals. The war on drugs failed long ago and only gave rise to organized crime, money laundering, murder, and the worlds largest prison population. People are going to experiment with drugs just as they have all throughout recorded history. At least, before this proposal, they knew what they were getting and where it was coming from so the manufacturer could be held accountable. Now, we will have illegal, underground labs selling chemicals made by a guy that is not trained in chemistry and has no idea what he is doing. People will use his product, they will get sick, injured, or die and he will never be held accountable. And those deaths will be a direct result of AED. AED will make criminals that make poison that kills people. That is a certainty. Bear in mind, these are words coming from a man who has had half his immediate family drink themselves to death or overdose, and understands the situation intimately. Treatment and education are the only proven methods for success. Not imprisonment, not prohibition, *TREATMENT* and *EDUCATION*. This was a program that was started to stop opiods, but its stopping everything. Its ruining the postal system, costing more tax money, costing consumers more money, and severely limiting our freedoms. Its not acceptable and its not the United States. The United States was founded on the idea of freedom, but its feeling more like a prison every day.  To the attention of Secretary Mayorkas:The American Consumer Institute Center for Citizen Research (ACI) would like to take the opportunity to address the Mandatory Advance Electronic Information for International Mail Shipments interim final rule (IFR) issued by the Department of Homeland Securitys U.S. Customs and Border Protection (CBP) to implement portions of the Synthetics Trafficking and Overdose Prevention Act (STOP Act; P.L. 115-271, Title VIII).  The Synthetics Trafficking and Overdose Prevention (STOP) Act was designed to help law enforcement and security agencies to identify and prevent hazardous substances, such as synthetic opioids and other dangerous items, from traveling through the U.S Postal Service (USPS) into the United States. ACI has touted the critical nature of such measures and has previously noted, The solutions created by the STOP Act will give law enforcement the tools necessary to begin stemming the intrusion of illicit items in the nations mail system. Specifically, this entails requirements on the USPS to collect and monitor advanced electronic data on shipments that enter the country. Such responsibilities would parallel the practices used by private delivery companies, which track every package and gather key data on the contents in order to assist coordination with U.S. Customs and Border Protection other federal securities entities. The STOP Act as written provides a clear schedule for accelerated levels of compliance that has allotted U.S. institutions to set their own frameworks for operational change and resource adjustments in order to meet objectives. The measures of the law are rightfully thorough in that they establish provisions for the myriad of elements of potentially exploitable delivery. The posture of the IFR as proposed would undermine this comprehensive configuration and thus jeopardize the overall purposes of the STOP Act.   In order to regain the trust of consumer communities in logistics and delivery markets, it is incumbent upon DHS to transparently detail the inflows of mail and packages and correspondingly provide data on the actions taken to assess each item, such that stakeholders and lawmakers can ascertain how exactly USPS and CPB are making good on assurances in this critical arena. The circumstances surrounding the origin of the law should remain apparent for the Department, and more broadly for the Administrations awareness. Unfortunately, for a 12-month period ending this past September, more than 87,000 Americans died of a drug overdose, surpassing the toll from any year since the opioid epidemic began in the 1990s.  The continuation of such trends heightens the concern for muting policies or laws that are actively working to prevent dangerous substances from entering our country. In a statement submitted by Robert Cintron Vice President, Logistics of United States Postal Service to the Permanent Subcommittee on Investigations of the Homeland Security and Governmental Affairs Committee, USPS was able to see the advance electronic data (AED) percentage for inbound international packages peak at 67 percent in January 2020, up from almost zero AED in the six years prior. While this is a demonstrated improvement, it is still cause for concern as the law called for an extensive grace period in the lead up to 100 percent compliance by January 1, 2021. Cintron admitted that AED progress reversed as the coronavirus pandemic affected international shipments but expressed his belief that once international mail recovers, he expects the AED will as well. While there is no accounting for the exact effect the coronavirus pandemic had on this effort, the USPS is still responsible for fulfilling its obligations.ACI further acknowledges and respects the USPS Inspector Generals role in assessing compliance, however concerns remain about the reticence of transparency and the redactions of key information that remain shielded from public review in their report.  Limiting the obfuscation in this regard, wherever feasible, and similarly elucidating the criteria through which foreign nations may be considered for any form exemptions, would represent prudent action on the part of the Department.In closing, we trust that the Department shall not be unduly influenced by the notions that enforcement of AED obligations could hypothetically prompt retaliation from foreign postal services.  Direct causation cannot be automatically assumed and such potential externalities are largely immaterial to actions dictated by the statutes of the law.  Ultimately, the STOP Act provisions must be held up to its full lifesaving potential in service to American consumers. Thank you for your consideration. Respectfully,Steve PociaskPresident/CEO American Consumer Institute1701 Pennsylvania Avenue, NW, Suite 200Washington, DC  20006 It is very interesting to see how the border crisis can relate to other issues and upcoming issues being brought to America. I didnt read too far into depth but I did not see any suggesting of the invar go created by Joe Biden, I wish there was more pictures of the border crisis just to get a gist of what is going on over there.