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Importer Security Filing and
Additional Carrier Requirements
10+2 Trade Outreach Webinar
Spring 2010
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Todays Presentation on 10+2
Overview of the ISFRequirements
Program Update
Enforcement Strategy
Top ISF Issues
Q & A Session Los Angeles - Long Beach Seaport
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What is the Security Filing?
Carrier Requirements:Vessel Stow Plans required for arriving vessels with containers.
Container Status Messages required for containers arriving via vessel.
The Security Filing, commonly known as the 10+2 initiative, is
a Customs and Border Protection (CBP) regulation thatrequires importers and vessel operating carriers to provide
additional advance trade data to for non-bulk cargo shipments
arriving into the United States by vessel.
Importer Requirements:
U.S. Bound Cargo: requires the electronic filing of an Importer Security
Filing (ISF) comprised of10 data elements (a.k.a., ISF-10).
Transit Cargo: requires the electronic filing of an ISF comprised of
5 data elements (a.k.a., ISF-5).
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Importer Security Filing (ISF) Importer
The party required to submit the Importer Security Filing (ISF) is
the party causing the goods to enter the limits of a port in theUnited States. This party is known as the ISF Importer.
Could be the owner, purchaser, consignee, or agent (e.g. customs
broker).
The ISF Importer, as a business decision, may designate an
authorized agent to file the Importer Security Filing on the ISF
Importers behalf.
If an agent is used for ISF purposes, a power of attorney (POA) is
required.
The ISF Importer is ultimately responsible for the timely,
accurate and complete submission of the ISF filing.
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ISF-10 Data ElementsU.S.-bound Cargo (3461 Entries, IT, FTZ)
1. Importer of Record Number2. Consignee Number
3. Seller (Owner) name/address
4. Buyer (Owner) name/address
5. Ship to Party
6. Manufacturer (Supplier) name/address7. Country of Origin
8. Commodity HTS-6
9. Container Stuffing Location
10. Consolidator (Stuffer) name/address
11. Bill of Lading Number (house or reg.)
12. ISF ImporterCBP Form 3461
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ISF ImporterImporter of Record #
Consignee #
Buyer (Owner)
Ship To Party
From Order to Delivery
Manufacturer (Supplier)
Seller (Owner)
ISF Importer
Ship To Party
Container Stuffing Location
Manufacturer (Supplier)
Consolidator (Stuffer)
ISF Importer
Seller (Owner) Purchase Order
Ship To PartyConsolidator (Stuffer)
Container Stuffing Location
Invoice
The ISF-10 is due 24 hours
prior to vessel lading
Overseas Factory/Warehouse Shipper/Carrier Distribution Center
Importer/RetailerVendor/Supplier
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ISF Filing Requirements All ISF filings are to be done electronically via the vessel
Automated Manifest System (AMS) or the AutomatedBroker Interface (ABI)
ISFs cannot be done at the Port of Entry (i.e., Custom House) on
a walk-in basis
There is no paper form
(e.g., 3461)
Bonds are required to cover
most ISF transactions
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ISF Filing Options
CBP has begun development of an internet-based web
portal to accept ISF filings Importers must pre-register their importer ID numbers with CBP (i.e., IRS#
or SSN#)
Registration of the importer ID number can be done in person at a local Port
of Entry or by a licensed customs broker via the use of CBP Form 5106
Portal will be available no earlier than August 2010
Use of the portal will probably be limited to no more than two (2) ISF filingsper day, with a maximum of twelve (12) per year
In addition, some service providers allow self-filers
indirect access to CBP systems via the internet
Contact a CBP Client Representative at 571-468-5500to discuss self-filing options
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10+2Interim Final Rule
Effective Date: The interim final rule (IFR) took effect on
January 26, 2009(60 days after the publication date) andallowed for certain flexibilities:
Timing of transmission for 2 of the 10 ISF data elements
Range of responses for 4 of the 10 ISF data elements
All other requirements in this rule were adopted as a finalrule.
Compliance (Enforcement) Date: January 26, 2010
The IFR flexibilities will stay in effect until the structured review is
completed and a decision on keeping, modifying or removing them ismade by DHS, OMB and other executive branch agencies.
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Structured Review and Flexible Filing
CBP monitors all ISF submissions for timeliness, accuracy and
completeness. On the basis of information obtained during the structured
review and public comments, DHS will undertake an analysisof the elements subject to flexibilities.
Analyze Flexible Range of Responses (FR) Elements Ship to Party
Manufacturer (Supplier) name/address
Country of Origin
Commodity HTS-6
Analyze Flexible Timing (FT) Elements Container Stuffing Location
Consolidator (Stuffer) name/address
Only 2% of all filings
claim to use the
flexible filing option
If you choose to use a
flexible option, you
MUST amend your
filing with a CT
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40 Container
NEW SECURITY FILING DATABED LINEN 630210 CN MFR/Supl. XINJIANG TOP BEDDING PRODUCTS
Seller XINJIANG TOP BEDDING PRODUCTS
Stuffing Location XINJIANG, CN Buyer BE & D IMPORT INC (PHX., AZ)
Consolidator XYZ LOGISTICS Importer BE & D IMPORT INC (PHX., AZ)
Ship ToName/Add. THE TRANSFER WHSE (L.B., CA) Consignee BE & D IMPORT INC (PHX., AZ)
ISF Data Improves Targeting Capabilities
Source Description HTS C/O Role PartyBILL OF LADING SHEET N/A N/A Shipper XYZ LOGISTICS
Consignee ABC TRUCKING
Whats in the box?
Non Intrusive Inspection (NII) X-Ray Image OnlyNII Image and Manifest Data
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What Are Casings?
ISF DataImproves Cargo Identification
Bullet Casings
Pipe Casings
Gear Casings Motor Casings
Computer Casings
Bomb Casings
Tire CasingsSausage Casings
HTS 1601.00
HTS 9306.30
HTS 7304.20
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10+2 Program Update
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ISF-10s By the NumbersJanuary 26, 2010 May 2, 2010
Impo rters (IOR #s):
2,453,200Tota l Subm issions:
Total Accepted:
Total Rejected:
2,372,907
80,293 3%
97%
123,000+
Filers: 2,226
79%
19%
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Top Five Error MessagesISF-10 Errors fromJanuary 26, 2010 April 25, 2010
0
10,000
20,000
30,000
40,000
50,000
60,000
Duplicate ISF Invalid ISFTransaction #
InvalidCountry
Code
Invalid HTS # Invalid IDCode
52,259
19,79117,502
13,231
9,010
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ISF Progress Reports
In production since May 10, 2009
Registration is Required
Reports are on a Monthly Cycle
Reports Cover122,251 ISF Importers
We Offer .pdf, .csv, and .xls Formats
Four Types Currently in Production: Importer by Filer Reports (most common) - Over1,105 ISF Filersare
registered
Filer Summary Report
C-TPAT Importer Reports (Tier 3, 2) C-TPAT Importer Transactional Reports (Tier 3)
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Importer Security Filing (ISF)
Progress Reports
1. ISF10 Submission Volume:
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C-TPAT Benefits of 10+2
Earlier Decision Making C-TPAT entities are reliably identified prior to vessel lading
Based on Importer of Record Number on the ISF
No longer tied solely to entry data (24 hours or more prior to arrival)
Better Decision Making
Tangible C-TPAT benefits are applied much further upstream Receive targeting credit based upon their tier status
Stabilization of Automated Hold Process
Immediate Transportation (IT) in-bond risk assessments are more stable
Validation of Supply Chain Security Reviews
New Entities and Locations Identified and/or Verified
Container Stuffing Location
Consolidator (Stuffer) name/address
Customs - Trade Partnership Against Terrorism
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10+2 Enforcement Strategy
CBPs Vessel Stow Plan Module
Used to identify unmanifested containers
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ISF Enforcement StrategyThe full compliance (enforcement) date for the 10+2
requirements commenced on January 26, 2010, thus ending a
12-month delayed enforcement period in which CBP provided
extensive outreach to educate the trade community on the new
requirements. CBP will:
Apply a measured, commonsense approach to enforcement
Exercise the least amount of force necessary to obtain full
compliance
Evaluate non-compliance on a case-by-case basis
Continue to provide outreach and guidance to the trade
X
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Enforcement Measures
Informed Compliance Efforts
Public outreach (incl. webinars, meetings, ISF Progress Reports) Informal and formal notification (e.g., warning letters)
Mid-level Compliance Measures
Domestic NII examination manifest holds
Domestic physical examinations
Re-evaluation and possible reduction of C-TPAT status
Strictest Enforcement Measures
ISF Jail (i.e., lengthier manifest holds)
Liquidated Damages
Suspension or Revocation of C-TPAT Status
Do Not Load or Do Not Discharge Orders
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10+2 Challenges
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Top ISF Issues Identified
How does CBP measure ISF Timeliness?
The regulation states 24 hours prior to lading (Legal) CBP will measure by the Vessel Departure Date minus 24 hours (Practical)
Which bill of lading number do I use?
Must use the lowest bill of lading transmitted in AMS (house orregular)
Contact your shipper
New ABI query functionality will help
CBP allows for the bill of lading number to be updated on the ISF
I cant get a bond because I missed the filing deadline
CBP is considering creating a Type 13 Late ISF coded transaction
Importers are acknowledging that they violated the regulations
Will probably not be available for longer than one (1) year
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Top ISF Issues Identified
I didnt receive the ISF Bill on File match message.
This is common; especially when the ISF filing precedes the filing of thecustoms manifest (i.e., bill info).
Make sure you (or your agent) annotated the correct bill type on the ISF.
Regular BillThis bill type is also referred to as an Ocean" or Simple Bill
and is issued by a Carrier. There are no underlying house bills.
House Bill Typically issued by a NVOCC (sometimes referred to as anautomated freight forwarder). A house bill of lading always falls under a
carriers Master bill of lading.
ISFs cannot be filed against Master Bills
Do NOT Send in a REPLACE to force an ISF-Bill Match message
Do I need to file 24 Hours prior to lading of the feeder ormother vessel?
The ISF is due 24 hours prior to lading of the mother vessel
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Available Resources
Go to: www.cbp.gov
Copy of the Interim Final Rule
ISF PowerPoint Presentation
General Frequently Asked Questions (FAQs) Document
Copy of the Regulatory Assessment
Implementation Guides (Technical File Formats)
Mitigation Guidelines
News Releases
Outreach Schedule
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Questions?
10+2 ContactsRichard Di Nucci, Director, Cargo Control Division
John Jurgutis, Branch Chief, ISF & Vessel Manifest
Stephen Silvestri, Branch Chief, Air & Rail Manifest
Craig Clark, Program Manager, ISF
Joseph Martella, Program Manager, New York Field Office
www.cbp.gov
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