Reminder: Avoiding ACE Data Errors that May Delay Payment of CBMA Importer Refund Claims
Our CBMA importer refund claims system relies on the information importers provide in CBP’s Automated Commercial Environment (ACE). If the CBMA data required in ACE is incorrect or missing and cannot be fixed, an importer may need to upload their claim and supporting documentation into the myTTB CBMA importer refund claims system, significantly delaying the review and payment of the claim. As such, it is extremely important that importers make sure, wherever possible, that their CBMA data in ACE is complete and correct.
While most CBMA data elements can be updated in ACE through a post-summary correction (PSC) prior to filing a claim, there is one notable exception:
The TTB Importer Permit Number, filed as part of the TTB PGA Message Set in ACE at the time of entry, cannot be updated once an entry summary is filed. The TTB Importer Permit Number is necessary to link an importer’s entry data to the myTTB CBMA importer refund claims system. Importers will receive a warning in ACE if the TTB Importer Permit Number entered is not valid. Importers who receive this error should correct the TTB Importer Permit Number before proceeding.
Other common errors have involved the TTB Foreign Producer ID and Controlled Group Name fields. TTB and CBP have published updated instructions for these fields in the ACE CATAIR (instructions begin on page 94). Note that both fields can be updated through a PSC.
Are Commercial Vinegar Producers Regulated by TTB?
 At recent conferences, we’ve been asked if TTB regulates vinegar producers. Yes, we do under certain circumstances! Many vinegar production methods include a stage where alcohol has developed but vinegar, with its distinctive sour taste, has not. TTB regulates commercial vinegar production when there is potential federal excise tax liability as beverage alcohol under 26 U.S.C. 5001, 5041, or 5051, at any stage of production, including on raw materials used to make the vinegar.
Information about the TTB requirements to produce regulated types of finished vinegar can be found in FAQ G7 and at TTB.gov.
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