Understanding ACE Release 3 Aggregation Rules & The 'One Person, One Day' Standard

1. Executive Summary: From Trust-Based to Algorithmic Enforcement

With the deployment of ACE Release 3, U.S. Customs and Border Protection (CBP) has fundamentally altered the operational landscape for Section 321 de minimis shipments. Moving beyond the passive advisory phase of Release 2, the system now employs hard-coded logic to enforce the statutory "One Person, One Day" limit found in 19 U.S.C. § 1321. This shift transitions compliance from a retrospective audit activity to a real-time gatekeeper mechanism, utilizing advanced data forensics to identify and halt shipments that exceed the $800 daily aggregate threshold per consignee.

This technical guide dissects the mathematical models driving ACE Release 3, specifically the treatment of "Ghost Consignees" and "Structuring" schemes. By automating the aggregation logic through the Estimated Date of Arrival (EDA) and utilizing address normalization standards similar to USPS CASS, ACE now generates immediate disposition codes (Code 34) that stop cargo release. Stakeholders must understand that this is not merely a policy update but a systemic implementation of algorithmic risk targeting that ignores minor variations in consignee data to prevent evasion.

2. Regulatory Architecture & Risk Context

To navigate the technical constraints of ACE Release 3, it is imperative to distinguish between the static letter of the law and the dynamic application of system rules. The architecture consists of three distinct layers: Statutory Requirements (The Law), ACE System Logic (The Hard Code), and Risk-Based Validation (The Targeting).

Statutory Law (The Mandate)

• 19 U.S.C. § 1321(a)(2)(C): Establishes the administrative exemption admitting articles free of duty/tax if the aggregate fair retail value imported by one person on one day does not exceed $800.
• 19 CFR § 143.23: Governs the Entry Type 86 (ET86) procedures, mandating that consolidated shipments addressed to one consignee be treated as a single importation for value purposes.

Operational Guidance (The Trigger)

• Trade Information Notice (Release 3 Deployment): Announces the shift from advisory messages to active withholding of release for shipments exceeding the daily threshold.
• CSMS #61421135: Mandates the submission of the Estimated Date of Arrival (EDA) for all ET86 submissions, establishing the temporal anchor for the aggregation logic.

System Logic (The Risk)

• The "One Day" Calculation: ACE aggregation is tied to the Estimated Date of Arrival (EDA) at the first port of arrival (normalized to Eastern Time), distinguishing it from the manifest creation date or the commercial date of sale.
• Normalization & Fuzzy Matching: ACE employs address standardization (stripping punctuation, standardizing suffixes like "St" vs. "Street") combined with fuzzy matching to identify "Ghost Consignees" attempting to bypass limits via slight name variations.

3. Technical Architecture: Disposition Code Hierarchy (34 vs. 2M)

The ACE system communicates aggregation status through specific disposition codes. Understanding the difference between a warning and a hard stop is critical for operational triage.

4. Logic Table: The "Scenario Matrix" — Structuring vs. Forensics

This matrix illustrates three specific structuring attempts (evasion schemes) and the forensic result generated by ACE's normalization logic. Any attempt to deliberately alter data to avoid aggregation is classified as a critical compliance risk.

5. Rapid-Fire Checklist: The Aggregation Logic Explainer

Before filing Entry Type 86, verify the shipment data against these core logic rules to predict potential aggregation holds.

• The Aggregation Key — Defined mathematically as: [Normalized_Consignee_Name] + [Normalized_Address] + [EDA].
• The "Calendar Day" Rule — Aggregation applies to all entries arriving on the same calendar day (12:00 AM to 11:59 PM ET) based on the EDA, not a rolling 24-hour window.
• PGA Distinction — Distinguish between a Value Aggregation Hold (Code 34) and a PGA Admissibility Hold (e.g., FDA). Code 34 is purely financial; PGA holds are regulatory.
• Address Hygiene — Ensure unit numbers are distinct and valid. Missing unit numbers in multi-tenant buildings (e.g., dorms) will cause false-positive aggregation.

6. Live Scrubber Preview: The "Detector" Ruleset

Paste your shipment snapshot into the Aggregation Risk Scrubber below to see how the ezenciel mini-agent normalizes names/addresses, groups by EDA, and issues a PASS or FLAG before ACE generates a Code 34. It is the same workflow our Section 321 agent runs before we ever transmit a Type 86 file.

Format each shipment block as Value, Consignee, Address, and EDA (Eastern Time) separated by blank lines so the scrubber can isolate each data set.

The scrubber handles the full workflow for you—address/name normalization, aggregation-key grouping, daily total calculation, and Code 34/2M risk narration—so operations teams can triage without reading pseudo code.

7. Operational Remediation Protocols

When ACE triggers an aggregation hold, immediate action is required to prevent storage demurrage and supply chain blocks. The response depends on whether the hold is a warning (2M) or a hard stop (34).

For Code 34 (Hard Stop)

1. Halt Movement: The cargo is legally detained at the system level. Do not attempt to move goods from the terminal.
2. Assess Value: Confirm if the aggregated total exceeds $2,500. If <$2,500, you may file an Informal Entry (Type 11). If >$2,500, a Formal Entry (Type 01) is mandatory.
3. Re-File Entry: Cancel the Type 86 and file the appropriate consumption entry (01/11), paying applicable duties and MPF.
4. Audit Source: Investigate the consignee data. If structuring is suspected (intentional splitting), flag the entity for internal blocked-party screening.

For Code 2M (Warning)

• Pre-Arrival Review: This code indicates a potential overage based on current EDAs. Review all pending shipments for this consignee scheduled for the same day.
• If the total will exceed $800 upon arrival, preemptively upgrade one of the shipments to Type 01/11 to avoid a Code 34 hold at the port.

8. Official References & Source Material

• 19 U.S.C. § 1321(a)(2)(C): The statutory basis for the $800 administrative exemption.
• CSMS #61421135: "Entry Type 86 Estimated Date of Arrival Requirement" (establishing the data key for aggregation).
• Trade Information Notice (CBP Publication): "Section 321 – Does Not Exceed $800 in Aggregated Shipments – Release 3."