CBP High-Risk Cargo Descriptions: Remediation & Syntax Standards

1. Executive Summary: The Data Quality Imperative in De Minimis Trade

U.S. Customs and Border Protection (CBP) has shifted to a strategy of "prescriptive data targeting" to manage the volume of Section 321 imports. Under recent enforcement campaigns, including Operation Mega Flex and the Entry Type 86 data pilot, vague descriptions such as "parts," "accessories," or "daily necessities" are now classified as high-risk indicators that trigger immediate manifest holds or "Do Not Load" orders.

This resource provides the authoritative "Red-to-Green" syntax standards required to navigate this enforcement environment. By operationalizing the requirements of 19 CFR § 128.21(a)(4) and mapping prohibited terms to compliant syntax patterns, logistics teams can eliminate data-quality holds and secure their participation in expedited entry programs.

2. Regulatory Architecture & Risk Context

The requirement for description specificity is not merely an administrative preference; it is a statutory mandate grounded in Title 19 of the Code of Federal Regulations, directly linked to national security screening.

Statutory Law (The Mandate)

• 19 CFR § 128.21(a)(4): Mandates that express consignment operators must provide a "specific description of the merchandise" in the advance manifest; general terms are legally insufficient.
• 19 U.S.C. § 1321: Establishes the de minimis exemption but clarifies that "Gift" is a release type, not a valid commodity description for manifest purposes.

Operational Guidance (The Trigger)

• CSMS #50484790 (2022): The foundational "Examples of Unacceptable vs Acceptable Cargo Descriptions" bulletin that established the official "Red/Green" list.
• CSMS #60144714 (2024): Operationalized the mandatory rejection policy, confirming that vague descriptions will result in "Do Not Load" orders in the ACAS environment effective November 12, 2024.

System Logic (The Risk)

• ACAS "72" Error (Do Not Load): High-risk vague terms in air cargo data trigger a security hold preventing the cargo from physically boarding the aircraft.
• Type 86 Program Suspension: Repeated submission of vague data serves as grounds for suspending a filer's privilege to use the expedited Entry Type 86 clearance process.

3. Technical Architecture: Decoding Rejection Signals

The "Section 321 Structuring Agent" must be programmed to interpret specific ACE Cargo Release status messages to automate the remediation loop.

4. Logic Table: Vague Terms vs. Compliant Fixes

The following table maps common vague terms (Red) to their compliant syntax patterns (Green), derived from CBP guidance and carrier bulletins.

5. Rapid-Fire Checklist

Before transmitting manifest data to ACE, run descriptions through this validation logic:

• No "Noun-Only" Descriptions — Flag any description consisting of a single word from the "Vague List" (e.g., "Parts", "Samples").
• Strip "Gift" Syntax — Remove the word "Gift" from the primary description field and replace it with the underlying commodity.
• Brand Name Validation — Ensure brand names (e.g., "Nike") are accompanied by a commodity noun (e.g., "Shoes").
• Material Attribute Check — Verify that items like "Bags," "Shoes," or "Bottles" include a material composition (e.g., "Leather," "Plastic").

6. Live Scrubber Preview

This tool tests cargo descriptions against the compiled "Red-to-Green" remediation matrix derived from CBP CSMS #50484790 and major carrier bulletins.

It identifies "Low Entropy" terms that lack sufficient informational density and suggests compliant syntax patterns to prevent ACE rejection.

7. Operational Remediation Protocols

When a hold occurs, immediate action is required to restore cargo flow and prevent storage fees.

For Code 613 (Manifest Hold)

1. Parse the SO20 Message: Identify the specific House Bill and the "CMT" text to confirm the vague term triggered the hold.
2. Request Invoice Detail: Contact the shipper for the commercial invoice to identify the specific commodity hidden by the vague term.
3. Map to HTS Syntax: Rewrite the description to match the HTSUS tariff description (e.g., change "Auto Parts" to "Brake Pads of Steel").
4. Transmit Correction: Send a Manifest Correction (CAMIR or 309 transaction) to update the data in ACE immediately.

For Code 72 (ACAS Do Not Load)

• Stop Movement: Ensure the cargo is physically segregated and not loaded onto the aircraft.
• Submit a new ACAS filing with the precise description immediately; the hold will only be lifted upon receipt of compliant data.

8. Official References & Source Material

• CBP CSMS #50484790: "Examples of Unacceptable vs Acceptable Cargo Descriptions"
• CBP CSMS #60144714: "Update on Vague Merchandise Description Cargo Messages (Enforcement Action)"
• 19 CFR § 128.21: Express Consignment Manifest Requirements