CBP Updates ACE HTS Reporting Order for Chapter 98 and 99 Classifications

Key Points

• CBP issued CSMS # 69668138 on August 27, 2026, updating the required order of reporting multiple HTS classifications on a single entry summary line when a Chapter 98 or Chapter 99 HTSUS classification is required or applicable.
• ACE is the system of record for all entry summaries, and incorrect line ordering can trigger processing errors or misfiled duty calculations, particularly for special tariff provisions reported under Chapters 98 and 99.
• ACE will undergo standard invasive production maintenance from 10:00 p.m. ET Saturday, August 29, 2026, to 4:00 a.m. ET Sunday, August 30, 2026, per CSMS # 69668727; plan filings accordingly.
• CBP is also collecting feedback through the voluntary, anonymous 2026 ACE User Satisfaction Survey, referenced in CSMS # 69647683.

On this page

1. What changed: updated HTS reporting order guidance
2. Why Chapter 98 and 99 classifications require special handling
3. ACE maintenance window: August 29 to 30, 2026
4. ACE User Satisfaction Survey
5. What importers, brokers, and compliance teams should do
6. Key references

CBP has updated its guidance on the order in which multiple HTS classifications must be reported on a single ACE entry summary line whenever a Chapter 98 or Chapter 99 HTSUS subheading is required or applicable. The updated guidance, issued August 27, 2026, applies to all entry summaries filed in ACE, which remains the system of record. Brokers and importers should review their ACE filing templates and software configurations immediately to confirm they match the new ordering rules before their next affected entry.

The links in this article go to the primary documents: the CSMS notices and official CBP guidance pages themselves. Read the source.

What changed: updated HTS reporting order guidance

CSMS # 69668138 revises the sequence in which filers must list multiple HTSUS classifications on the same entry summary line when a Chapter 98 or Chapter 99 heading or subheading is required and/or applicable. CBP states that ACE is the system of record for all entry summaries, meaning deviations from the prescribed ordering are not merely stylistic issues. They affect how ACE processes the entry and calculates duties.

The CSMS message does not repeal any prior filing requirement. It updates the ordering rule, which means existing entry summary templates, customs broker software configurations, and internal filing checklists that reference the old guidance need to be reviewed against the new version.

Why Chapter 98 and 99 classifications require special handling

Chapter 98 of the Harmonized Tariff Schedule of the United States (HTSUS) covers special classification provisions, including goods returning to the United States and items eligible for reduced or zero duties based on their origin or treatment. Chapter 99 is the vehicle through which temporary trade measures, including Section 301 and Section 232 additional duties, exclusions, and tariff-rate quota provisions, are administered. When an entry line carries both a standard commodity classification and a Chapter 98 or 99 code, the sequence in which those codes appear in ACE directly affects which duty rates are assessed and whether special provisions are correctly recognized.

Filers reporting Section 301 additional duties, Section 232 steel or aluminum duties, or any active exclusion must pay close attention to this guidance, as those provisions live entirely within Chapter 99. An incorrect ordering on a line that also carries a Chapter 98 provision could produce an erroneous duty bill or cause ACE to reject the entry.

ACE maintenance window: August 29 to 30, 2026

Separate from the HTS ordering guidance, CSMS # 69668727 announces a standard invasive maintenance window for the ACE production environment. ACE will be unavailable from 10:00 p.m. ET Saturday, August 29, 2026, to 4:00 a.m. ET Sunday, August 30, 2026. During invasive maintenance windows, entry summary submissions, cargo release transactions, and other ACE interactions may be disrupted or unavailable.

Filers with time-sensitive entries, particularly those approaching cargo release deadlines or with entries that need to reflect the updated Chapter 98/99 ordering, should complete those submissions before 10:00 p.m. ET on August 29 or plan to file after 4:00 a.m. ET on August 30.

ACE User Satisfaction Survey

CBP is also soliciting feedback on the ACE platform through its 2026 ACE User Satisfaction Survey, noted in CSMS # 69647683. The survey is voluntary and anonymous. CBP states that a high response rate will help the agency understand user satisfaction with ACE capabilities and user experience. Brokers and importers who work with ACE daily are the audience CBP most needs to hear from on system performance and usability.

What importers, brokers, and compliance teams should do

• Pull CSMS # 69668138 and compare the updated HTS ordering requirements against your current ACE filing templates, broker software settings, and any internal standard operating procedures that reference how to sequence Chapter 98 or 99 codes on multi-classification entry lines.
• Schedule any time-sensitive ACE filings to be completed before 10:00 p.m. ET on August 29, 2026, or after 4:00 a.m. ET on August 30, 2026, to avoid the invasive maintenance window.
• Consider completing the voluntary 2026 ACE User Satisfaction Survey to provide CBP with direct feedback on system performance.

Key references

• CSMS # 69668138: Updated guidance on ACE entry summary order of reporting for multiple HTS when Chapter 98 or 99 classifications are required (August 27, 2026).
• CSMS # 69668727: ACE production standard invasive maintenance notice, 10:00 p.m. ET August 29 to 4:00 a.m. ET August 30, 2026.
• CSMS # 69647683: 2026 ACE User Satisfaction Survey reminder (August 27, 2026).
• HTSUS online edition: Official Harmonized Tariff Schedule of the United States, including Chapters 98 and 99.