Comment submitted by Reinaldo Rodriguez, Customs and Trade Services, Inc.

Docket ID USCBP-2005-0009 Long Title Country of Origin of Textile and Apparel Products It is my understanding that the Automated Invoice Interface (AII) module of ACS/ABI can only handle one manufacturer I.D. code per commercial invoice. Remote Location Filing (RLF) is crucial for the processing of certain types of entries through different ports in the country from a single remote location. AII is mandatory for RLF processing. If goods are being sold by shipper "A" overseas to consignee/importer of record "B" in the United States, a single commercial invoice will be issued by "A" for the transaction, even though "A" my have sub-contracted the actual manufacturing of the goods to multiple vendors overseas. Under this scenario and based on the new Interim Regulation, the Customs entry will need to show as many manufacturer I.D. codes as actual manufacturers that confered the origin to the product were involved in the production of the goods, thus, making these entries ineligible for processing through AII and RLF. Is CBP capable of accepting multiple MID codes per invoice for AII/RLF purposes? If the answer is no, are we not defeating the big automation push? Thank you.