The "10" OF THE RULE is known as the ISF (Importer Security Filing). Under the proposed regulations, an ISF would be required for almost all shipments. As the responsible party, the importer or their authorized agent must transmit 24 hours prior to vessel loading. The "2" of the rule are additional information transmitted by the carrier. The vessel stow plan which is about the cargo's physical location on a vessel bound for the United States and a container status messages, which report container movements and change in status(e.g., container empty or full).

The EFFECTIVE Date (the latest estimate from Customs) is that if DHS and OMB promptly approve its intended revisions, the regulations regarding "10+2" security could be published as soon as the summer of 2008. CBP has said it will phase in enforcement of the rule over 12 months following the final regulation.

The CHALLENGE will be the compilation of this data from the multiple parties involved and the transmission of same in an accurate and timely manner. A number of the 10 elements aren't found on entry documents or commercial invoices and may be difficult to obtain. To comply, importers will need 100% visibility into their supply chains 24-48 hours prior to overseas loading.

• 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"

  The TRANSMISSION is the current approved electronic data interchange system, the Automated Broker Interface (ABI). As an ABI filer, John S. Connor, Inc. is working with our software vendor to facilitate a successful filing strategy for the importer by mapping the elements we already have in our data base with the remaining required elements from any supply chain partner.

  ISF (Importer Requirements) - 10 Data Elements)
  1. Manufacturer/supplier-can use party used for MID purposes; consistent with CBP Form 3461*.
  2. Seller-consistent with invoice requirement.
  3. Buyer-consistent with invoice requirement.
  4. Ship to--unique.
  5. Container stuffing location-unique.
  6. Consolidator-unique.
  7. Importer of record-consistent with CBP Form 3461.
  8. Consignee-consistent with CBP Form 3461.
  9. Country of origin-consistent with CBP Form 3461*.
  10. Commodity HTSUS no-consistent with CBP Form 3461*.
• Customs expects the ISF to link at the line level.
  Additional criteria: Master and house Bill of Lading.
  (Click here for additional information)
  http://e2ma.net/go/1099707672/997590/36547159
  http://e2ma.net/go/1099707672/997590/36547160
  
  To PREPARE, begin taking the following steps to ensure that you are prepared when the ISF final rule is published and implemented.
  1. Validate who the actual manufacturer is, if other than the seller
  2. Validate who, where and how your containers are being stuffed*
  3. When issuing your purchase order, instruct the vendor to supply the above elements which should be indicated on the commercial invoice.
  4. Initiate discussions today with your vendors of the ISF security filing requirements, requesting that they must make available the information at least 72 hours prior to loading of the vessel.
  5. Nominate authorized agent who will be submitting the ISF security filing on your behalf. (Who is most likely to have direct knowledge of the required 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.