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JOHN S. CONNOR, INC. HELPING YOU THROUGH THE CRITICAL MAZE OF ISF (10+2 ) AND THE REQUIRED IMPORTER SECURITY FILING
On January 2, 2008, the U.S. Customs and Border Protection (CBP) announced a Notice of Proposed Rulemaking (NPRM) that would require importers and carriers to electronically submit an Importer Security Filing (ISF) and Additional Carrier Requirements (commonly referred to as 10+2) before cargo is permitted entry into the United States by vessel. The phase in enforcement began on January 26, 2009 with enforcement to take affect on January 26, 2010.
ISF(10 + 2) will drastically change how Importers operate if for no other reason than it mandates new data elements which must be filed 24 hours prior to loading at the port of export. The Importer Security Filing (ISF) requires ten data elements while the carrier requirements are two additional data elements concerning cargo that will be imported into the United States.
The ten data elements required in the Importer Security Filing (ISF) include:
- Manufacturer's (or supplier's) name and address
- Seller's (or owner's) name and address
- Buyer's (or owner's) name and address
- Ship-to name and address
- Container stuffing location
- Consolidator (stuffer) name and address
- Importer of record number/foreign trade zone applicant identification number
- Consignee number(s)
- Country of origin
- Commodity Harmonized Tariff Schedule number
Although, not a required data element, the Bill of Lading number is the identifier between the AMS manifest and the ISF transmission. Therefore, the Bill of Lading number to the lowest AMS filing is required for filing.
As stated above, the drastic change for importers is this data must be reported 24 hours prior to loading. Importers naturally have raised reasonable questions such as what happens if I try my best but am unable to obtain the information, or it turns out to be wrong. You must obtain the information relying on due diligence and if you find out it was wrong and the shipment has not yet arrived, you must update your Importer Security Filing (ISF).
(Click here for FAQ U.S. Customs)
Importers will report these filings through AMS (manifest) or ABI (entry), the current platforms used by carriers and customs brokers. As both an AMS and ABI filer, John S. Connor is engaged in updating our software to accommodate these changes.
The other noteworthy topic was the portion of the NPRM which deals with penalties. For Importers, penalties are $5,000 per violation.
(Click here for CBP published Penalty, Mitigation Guidelines for ISF).
CBP is placing the burden of responsibility on the importer or their authorized agent to file this information and to be in control of their supply chain. John S. Connor will be prepared to support our clients in complying with this new regulation and the filing of same.
Importers will need to:
- Anticipate difficulties in obtaining the information needed to comply
- Train suppliers and shippers to provide the information in a timely manner
- Establish a reliable flow of information to the designated filer/authorized agent.
- Proactively plan for delays in the supply chain as a result of the "10+2"
More information
Can your company comply with the new rules under the Proposed-Importer
Security Filing - 10+2?
Contact Priscillar@jsconnor.com, Butchc@jsconnor.com for more information. |
