Pre Trade Compliance Consultants Discuss CBP

By: James Anzalone | Posted: 24th March 2010

U.S. Customs and Border Protection (CBP) has published on January 2, 2008 a Notice of Proposed Rulemaking (NPRM) requiring importers and carriers to electronically submit additional information on cargo before it is brought into the United States by vessel. The Security Filing, also known as "10+2," is another step in the Department of Homeland Security's (DHS) strategy to better assess and identify high-risk shipments to prevent terrorist weapons and materials from entering the United States.

While the aim of the initiative is indeed noble, importers and their forwarders / brokers should understand how this initiative affects them. The proposed regulation will require a single party designated by the importer of record to submit an Importer Security Filing (ISF) containing the following ten data elements at the lowest bill of lading level:

1. Manufacturer (or supplier) name and address
2. Seller (or owner) name and address
3. Buyer (or owner) name and address
4. Ship-to name and address
5. Container stuffing location
6. Consolidator (stuffer) name and address
7. Importer of record number/foreign trade zone applicant identification number
8. Consignee number(s)
9. Country of origin, and
10. Commodity Harmonized Tariff Schedule number (6 digit)

The ocean carrier will be required to submit (1) a vessel stow plan used to transmit information about the physical location of cargo loaded aboard a vessel bound for the U.S; and (2) container status messages, which report container movements and changes in status (e.g., empty or full).

The good news is that most of these elements are already included in existing entry documentation. The bad news is that CBP will require importers or their agents to transmit this information (ISF) to CBP no later than 24 hours before cargo is laden aboard a vessel destined to the United States.

Can your supply chain handle these requirements?

* Can your foreign seller or its agents provide you with this info prior to lading?
* How will you know that the HTS is compliant?
* Can you provide the container stuffing info 24 hours prior to lading?
* Do you know the buyer of your cargo prior to entry?

These are the importer's requirements and your forwarders / brokers are not responsible for managing this initiative - you are! If you are not already, you should be discussing these requirements with your broker now. How will "10+2" affect you?

For more information on “10+2” and pre trade compliance please visit us at http://www.wearecompliant.com
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Tags: physical location, name and address, high risk, department of homeland security, number 6, number 8, customs and border protection