|APIS Regulatory Requirements vs. eAPIS Data Field Requirements – Why are they different?
Let’s start with defining the difference between APIS and eAPIS.
APIS is CBP’s Advance Passenger Information System; an automated record processing system capable of performing database queries on commercial airline, commercial vessel, and private aircraft passengers and crewmembers prior to their arrival in to or departure from the United States. Through APIS, CBP can identify high-risk travelers who may pose a risk or threat to vessel or aircraft safety or to national security, while simultaneously facilitating the travel of legitimate passengers and crew members.
eAPIS, the electronic Advance Passenger Information System, is a CBP web portal through which APIS manifest data can be submitted.
Since eAPIS is only a means of getting APIS manifest data submitted, the eAPIS systematic rules may seem a bit different than the APIS regulations. To help ensure that eAPIS users submit the minimum mandatory data elements needed to process a manifest, eAPIS marks some fields as “mandatory” (with a red asterisk). It’s a common mistake to confuse these web rules with APIS regulations and to think that you should only fill in data for the red-asterisk fields.
So what data is required? We are often asked, “Why aren’t all the fields in eAPIS ‘mandatory’? Which fields are really required?”
A good example of this difference is the “middle name” field. Because not all travelers have a middle name, eAPIS does not mark the field as “mandatory” with a red asterisk – manifests can be processed without middle names. But, APIS regulations require middle name submissions from all travelers – when applicable.
“So how do I know whether to submit the data?” If a traveler has a middle name listed in his passport, the required data is applicable and the data must be included in the APIS manifest (even though there isn’t a red-asterisk).
The bottom line is if the required information is available or applicable, it must be included in the APIS submission.
Submitting of Inaccurate APIS Information – Is it happening?
The short answer is, “Yes.” Some pilots are submitting information that is inaccurate, incomplete, invalid, and/or incorrect. And, yes, these types of submissions are subject to penalty case initiation.
The Address While in the United States field should reflect where the traveler will stay, or did stay while in the United States. A submission of “XX”, “NA”, or “don’t know” is an invalid and inaccurate submission.
It should also be noted that traveler biographical information should be submitted exactly as it appears on/in the DHS-approved travel document (passport, Alien Registration Card, etc.). A common example of biographical information errors is found in first name field submissions. If the traveler’s name is listed in a passport as “Edward”, don’t submit “Ed”.
The private aircraft pilot is the responsible party for ensuring that accurate, complete, valid, and correct data is transmitted in the APIS manifest. As the responsible party, the pilot of the aircraft may be subject to penalty for the inaccurate, incomplete, invalid, and incorrect submission of data in an APIS manifest.
In every case of non-compliance, the pilot will be contacted directly by this office to ensure that both sides of the story are considered before penalty case initiation occurs. Cooperative conversation and immediate, corrective measures go a long way in preventing penalty case initiation.
While hundreds of pilots have been contacted regarding “missing” manifests, “forgotten” submissions, and inaccurate, incomplete, invalid, or incorrect data submissions, as of November 2010, less than five (5) private aircraft pilots have been the subject of APIS penalty case initiation since the May 18, 2009 Private Aircraft APIS implementation.
eAPIS Online Help – Where is it?
While we receive many comments saying that no help is available within eAPIS, we want to remind you that if you need immediate assistance when submitting an APIS manifest through eAPIS, there are always two online resources available to you:
eAPIS Field Help - when you have questions about a specific field, field help is available by clicking on the underlined word(s) above the field; and
Frequently Asked Questions (FAQs) – FAQs are available by clicking on the red “Help” button in the upper right corner of eAPIS.
A third resource available outside of eAPIS is the Private Air APIS Guide. The guide contains an explanation and information concerning the format of every APIS data field. We’ve attached a copy to this newsletter, but it can also be found at www.cbp.gov.
CBP User Fee Decals – How do I get a 2011 decal?
January 2011 is just around the corner. 2010 CBP User Fee Decals will expire on December 31, 2010, and a new User Fee Decal for year 2011 will be required for aircraft arriving on and after January 1, 2011. The CBP User Fee Decal system is operated by the Decal and Transponder Online Procurement System (DTOPS). For additional information regarding CBP User Fee Decals or to access DTOPS visit the DTOPS website at https://dtops.cbp.dhs.gov/.
We hope this information is helpful. If you have any questions, concerns, or suggestions for newsletter content, please contact Private.Aircraft.Support@DHS.gov.
Thank you for your continued compliance.
Ralph D. Modisette National APIS Account Manager U.S. Customs & Border Protection Office of Field Operations