U.S. Customs Import Security Filing Initiative Hits Stride and a Few Bumps

(Jessica Paviluk — LOG-NET, Inc. Via PR Newswire)

Importer compliance volume is growing rapidly while responses and reporting issues grow with CBP

The volume of importers electronically filing advanced information to the U.S. Customs and Border Protection (CBP) division of the Department of Homeland Security is growing rapidly as the deadline for compliance looms, advised LOG-NET, Inc., a leading international supply chain software and service provider. The Importer Security Filing (ISF) initiative requires importers to provide significant advance information about the parties involved in import transactions to enable security screening before cargo is loaded to a vessel. Penalties for non-compliant importers begin in January 2010. The industry has been aggressively retooling centuries old trade practices in order to get the information to the CBP prior to loading the cargo for U.S. shores.

Average processing speeds decrease In the past month, increases in volume seem to have slowed the responsiveness of the CBP. Response to electronic filings had the following performance via the LOG-NET system:

Average Time for CBP to respond:
1.81 minutes, up from 1.76 minutes in the prior month

Median Time for CBP to respond:
1.83 minutes, up from 1.80 minutes in the prior month

Fastest Response Time:
17 seconds, up from 11 seconds last month

Slowest Response Time:
4.86 minutes, down from 14.9 minutes

The continuous improvement in the slowest response time was significant as it shows CBP reducing system exceptions that delay replies. However, this improvement should have allowed average responses to improve in speed and it did not. While CBP continues to keep their commitment to responding within 2 minutes, the slight increase in response time is worth watching as full volumes begin over the coming months.

Delays in report improvements begin to cause increased frustration among importers

As importers focus on the timeliness of the information, reporting to the CBP has had some shortcomings that continue to go unaddressed. Monthly report cards issued to the trade are designed to enable importers to determine the volume and timeliness of their compliance. The most recent round of reports was issued on September 8th to the importers who are filing.

Timeliness, per the regulations, is based on the time the ISF is submitted in advance of being laden aboard the vessel departing for the United States. CBP is presently reporting the time the importer files the ISF versus the time the carrier files the Bill of Lading. Carriers are under similar pressure to transmit their manifest of Bills of Ladings to the CBP. This subtlety of reporting on the Bill of Lading filing date instead of the sailing, or lading, date will cause some importers who have complied with the regulation to appear to have filed late. It is hoped that the CBP will improve this reporting in the future.

Enterprise logistics software, such as LOG-NET, maintains cross references between documents, shipments, filings, and orders and can benchmark compliance of both the importer and the CBP.

Importers should not delay in implementing the requirements of this regulation
Many importers are still not filing their ISF information. This data is vital for maintaining a resilient international trade system. With solutions like LOG-NET that make the process easy and efficient, there is no reason to delay.

In general the CBP has been doing an outstanding job of promoting the initiative and holds outreach programs throughout the country. With the Thanksgiving and holiday season approaching, there is limited time to get processes in place even if the technology is readily available and relatively inexpensive.

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Note: The foregoing is presented for information purposes only. GHY International does not necessarily endorse or recommend the product(s) referenced in this article.