Do AES Corrections make sense?

Submitted by an ICPA member

In a recent response to an inquiry regarding AES horror stories, there was mention of routing changes by couriers due to the volcanic disturbances over the North Atlantic which caused the port of export to change. It was mentioned that if this detail was not corrected, the > filer would be subject to a hefty penalty. We understand that AES filings serve two major purposes - [1] providing > statistical data on value, reporting units per HTS [Sch B] to which foreign destinations and [2] advising where the shipment is located so an inspection could be made, if desired. We file our own AES - [99.75% accuracy over 5 years vs. 1.3% accuracy when we did not file our own] Our freight forwarder automatically emails "confirmed on board" notices for air and ocean shipments. The couriers do not. Any last minute change in the port of export does not affect the "balance of payments" data that is being collected. Is it really necessary to submit a change in the port of export - after the goods have been exported? What purpose does it serve? With over a thousand courier exports per month, this would be a monumental task to track each shipment to verify the flow from shipping point to final departure from the US. Our inquiries to Census have resulted in "accurate data is required". Does that mean a change in weight from 12,500 kgs to 12,499 kgs should be corrected? A reported departure of Friday, was actually exported on Saturday. Does that need to be corrected? Some of these variances do not seem to be significant. Having to hire additional staff just to revise these minor changes would not be acceptable. The result would be a decrease in the number of exports as we find them to be too costly to monitor. I thought our government wanted to promote exports. We have cleaned up the accuracy of data submission over the last several years, but do not think it is fair to the exporting community to become mired down in insignificant adjustments. Our audits of Routed Transactions indicate that most of them reflect shipping data far different from what we provided. This is not easily auditable by the government [that is why the values, classifications, etc are changed]. We cannot believe that so much "garbage" is accepted and then penalties will be issued for a change in departure airports!