DIS: ACE Document Image System Explained for Customs Brokers

Key Points

• DIS (Document Image System) is the ACE channel brokers and importers use to send document images and structured documents tied to a specific entry, entry line, in-bond or PGA line.
• Some DIS uploads are proactive at importation, such as the mill analysis or mill test certificate for iron or steel of chapter 72 and headings 7301 to 7307 under 19 CFR 141.89(a), as described in CSMS # 50930928.
• Other DIS uploads answer a CBP or partner agency documents-required request, and CBP officers and agencies review them in ACE.
• FDA documents go to ITACS, not DIS, and a DIS upload is never a substitute for an entry filing or a PGA message set.
• Label codes, file limits and retention rules are set in the ACE DIS Implementation Guide (CBP, 2026 editions); confirm current values there before transmitting.

On this page

1. At a glance
2. What is DIS used for in ACE?
3. When are documents submitted through DIS?
4. How does a DIS submission work?
5. Common DIS errors and what they cost
6. How does DIS relate to other ACE functions?
7. Frequently asked questions
8. What importers and brokers should do
9. Key references

DIS, the Document Image System, is the U.S. Customs and Border Protection (CBP) channel in the Automated Commercial Environment (ACE) through which filers transmit electronic images and structured documents, such as invoices, certificates, permits and mill test certificates, linked to an entry, an entry line, an in-bond movement or a PGA line. Customs brokers, and importers filing through an ABI provider, use DIS either at importation when a program requires a document or after release when CBP or a participating agency asks for documents. CBP officers and participating agencies then review the images inside ACE.

This entry reflects the position as of October 2026. The links in this article go to the primary documents: the regulations, CBP messages and official program pages themselves. Read the source.

At a glance

• Full name: Document Image System (DIS)
• Who prepares or uses it: Customs brokers and importers (directly or through an ABI provider) submit; CBP officers and participating government agencies review
• When in the lifecycle: At importation where a program requires a document, or in response to a documents-required request
• System or channel: ACE, through ABI and the DIS transmission formats in the ACE DIS Implementation Guide
• Governing authority: Program-specific rules such as 19 CFR 141.89(a), plus CBP guidance including CSMS # 50930928 and CSMS # 62582900
• Label codes and file limits: Confirm with CBP in the current ACE DIS Implementation Guide
• Related terms: ACE in-bond, ACE protest module, ACE reconciliation, ACE AD/CVD case management, ACE truck eManifest

What is DIS used for in ACE?

DIS exists so that supporting documents for a customs transaction can travel electronically to CBP and partner agencies instead of on paper. Each DIS upload carries the document image or structured file, a DIS document label code that tells the reviewer what kind of document it is, and a reference that ties it to the transaction: an entry number, a specific entry line, an in-bond number, or a PGA line.

Typical DIS documents include commercial invoices, certificates of origin or compliance, permits, licenses and mill test certificates. The value of DIS is that the reviewing officer or agency analyst opens the document directly against the transaction in ACE, rather than chasing paper across a port.

DIS is narrow in one important respect: it carries documents, not data elements. It does not replace the entry, the entry summary, or any PGA message set. A filer who keys the required data and also uploads supporting images in DIS has done two separate things, and both must be right.

When are documents submitted through DIS?

DIS submissions fall into two broad patterns: proactive uploads that a program requires at importation, and reactive uploads that answer a request.

Proactive DIS uploads at importation

Some programs require a document to accompany the entry. The clearest example is steel. Under 19 CFR 141.89(a), entries of iron or steel classified in chapter 72 and headings 7301 to 7307 of the Harmonized Tariff Schedule require a mill analysis or mill test certificate. CBP's CSMS # 50930928 explains that steel mill certificates and aluminum metal-component statements are submitted in DIS at the time of importation. An EPA vehicle label image is another example of a document filers send proactively.

Reactive DIS uploads after a request

The more familiar DIS workflow begins when CBP or a participating agency issues a documents-required request on an entry or line. The broker then retrieves the requested document from the importer, applies the correct DIS label code, references the right entry or line, and transmits it. Reviewers see the upload in ACE and either clear the hold, ask for more, or take further action. Response timeframes are set by the requesting office; confirm them on the request itself or with the port.

How does a DIS submission work?

A DIS submission is transmitted by the filer through its ACE connection, following the record formats and label code tables in the ACE DIS Implementation Guide (CBP, 2026 editions). Three things must be correct on every upload:

• The document label code: it tells CBP or the agency what the document is. This article does not list codes; take them from the current implementation guide.
• The transaction reference: entry number, line number, in-bond number or PGA line, exactly matching the record in ACE.
• The document itself: legible, complete, and the version the program or request actually asks for. File format and size rules are in the implementation guide.

Uploads tied to movements under ACE in-bond (the electronic in-bond system in ACE, covering the QP/WP application, arrival and export messages, the in-bond number and the 7512 data) reference the in-bond number rather than an entry. Truck shipments arrive on an ACE truck eManifest (ACE e-Manifest: Trucks, the electronic truck manifest highway carriers transmit before arrival at a land border port), but documents for the resulting entry still go through DIS against that entry, not through the manifest. Also review CSMS # 62582900 for current CBP instructions bearing on DIS.

Common DIS errors and what they cost

DIS errors usually do not stop a transmission; they stop a review, which is worse because the filer may believe the job is done.

• Wrong label code: the reviewer cannot find the document type it requested, so the hold stays in place.
• Image tied to the wrong line: a mill certificate attached to line 3 when the steel is on line 5 leaves line 5 unsupported.
• Wrong channel: uploading to DIS when the agency wants its own portal. FDA documents belong in ITACS, not DIS, and FTZ e214 documentation follows its own process.
• Treating DIS as a filing: an image of a permit is not the PGA message set, and an uploaded invoice does not correct entry data. Data problems need the proper data correction.

The costs are practical: cargo held longer, storage and demurrage, repeat requests, and a weaker compliance record with the reviewing office.

How does DIS relate to other ACE functions?

DIS is a supporting channel that sits beside several other ACE functions, and confusing them is a common source of misfiled documents.

• ACE AD/CVD case management: the ACE function and public ADCVD Search through which CBP publishes Commerce's antidumping and countervailing duty case data. Case numbers are keyed on entry lines; DIS only carries any supporting documents CBP requests.
• ACE protest module: the ACE Secure Data Portal function for filing, amending and tracking protests (the electronic CBP Form 19) under 19 U.S.C. 1514 and 19 CFR part 174. Protest support travels with the protest, not as a free-standing DIS upload.
• ACE reconciliation: ACE Reconciliation (entry type 09) flags and later closes undeterminable value, classification, 9802 or FTA issues. DIS does not reconcile anything.
• proxy TAO: the ACE Trade Account Owner proxy who manages portal users and permissions; see our proxy TAO guide.
• Reporting: line data in ES-002 (ACE Reports ES-002 Entry Summary Line Details, the line-level entry summary report) helps match a DIS upload to the correct line; see our ES-002 article. Field meanings are in the ACE Reports data dictionary (CBP's reference defining each ACE Reports data object), covered in our data dictionary article. The same data appears in ACE Reports Modernized, the rebuilt reporting platform. Importers auditing older filings sometimes still rely on ITRAC (Importer Trade Activity data requested from CBP under the Freedom of Information Act).

Frequently asked questions

Is a DIS upload the same as filing an entry?

No. A DIS upload delivers a document image or structured document against an existing transaction; the entry, entry summary and any PGA message set must still be filed with correct data.

Do steel mill certificates go through DIS?

Yes. Under 19 CFR 141.89(a) and CSMS # 50930928, the mill analysis or mill test certificate for iron or steel of chapter 72 and headings 7301 to 7307 is submitted in DIS at the time of importation.

Can FDA documents be sent through DIS?

No. FDA documents go to ITACS, not DIS. Check which channel each agency specifies before uploading.

Where do I find DIS label codes and file limits?

DIS label codes, file format rules and size limits are in the ACE DIS Implementation Guide (CBP, 2026 editions). Confirm current values there or with your ABI provider rather than relying on older lists.

What importers and brokers should do

1. Map every product line requiring a proactive DIS document, starting with chapter 72 and headings 7301 to 7307 steel, and build the upload into the entry workflow.
2. Check the label code and the entry, line or in-bond reference against ACE before every DIS transmission.
3. Confirm the correct channel for each agency, sending FDA documents to ITACS and keeping DIS for documents CBP or the agency expects there.
4. Download the current ACE DIS Implementation Guide and read CSMS # 50930928 and CSMS # 62582900 with your ABI provider.

Key references

• 19 CFR 141.89: invoice requirements, including the mill analysis or mill test certificate in paragraph (a).
• CBP Cargo Systems Messaging Service: source for CSMS # 50930928 and CSMS # 62582900.
• CBP ACE program pages: location of the ACE DIS Implementation Guide (CBP, 2026 editions).
• Harmonized Tariff Schedule: chapter 72 and headings 7301 to 7307.
• 19 U.S.C. 1514 and 19 CFR part 174: protest authority behind the ACE protest module.