CBP Releases “10+2” Technical Requirements

(American Shipper – Eric Kulisch)

U.S. Customs and Border last week posted its draft technical requirements for a proposed security measure to collect more detailed, advance information on import cargo, known as “10+2.”

Agency officials have observed a quiet period while fielding public comments and preparing a final rulemaking, but import industry representatives have been pressing since the beginning of the year for a policy-free dialogue to get a head start on complex programming changes needed to properly transmit the Importer Security Filing.

The proposed rule requires importers to file 10 types of data identifying the manufacturer, consolidator, buyer and receiver of the goods 24 hours prior to vessel loading overseas. Ocean carriers must transmit two sets of data related to each container.

The publication of the data layouts indicates the agency is ready to begin discussions with the trade community about the design of the input fields and other technical matters needed to implement 10+2, which CBP officials predict will be released in final form later this summer. Programming issues to be resolved include the size of the data fields, how alphanumeric characters are used to describe records, and other coding.

Richard DiNucci, program manager for 10+2 in the Office of Field Operations, said at the May 9 meeting of the Commercial Operations Advisory Committee in Washington that his team was gearing up to discuss technical issues with industry. CBP officials indicated that COAC should take the lead in coordinating the talks with the industry. COAC members, in turn, have said they are prepared to delegate the data field layouts and electronic protocols to the Trade Support Network’s supply chain security committee. DiNucci said Customs may start gathering technical input at the June meeting of the Customs Electronic Systems Action Committee.

CESAC typically deals with information technology issues related to the electronic interfaces between ocean carriers and CBP, such as the Automated Manifest System. It likely will deal with the two data sets – stowage plans and container status messages – carriers must file under the rulemaking.

The TSN is a large gathering of industry representatives that provides Customs with feedback on agency modernization efforts. It is the logical place to examine the technical aspects related to the importer filing requirements, according to COAC members mingling at the American Association of Exporters and Importers Conference in New York on Monday.

The Department of Homeland Security is reviewing the final rule, which takes into account about 200 formal comments submitted by industry. DHS indicated in a document earlier this year that the Importer Security Filing would be finalized by September, but DiNucci said that date was included as a process formality, not as a hard timeline. The department is still trying to publish the final rule this summer, he said.

The Office of Management and Budget will reconsider its original cost-benefit analysis, which some industry representatives feel understated the potential implementation costs, as part of the process, DiNucci said.

To see CBP’s draft layout for 10+2 data transactions, go to the CBP website.