(World Trade Interactive)
The Import Security Filing Subcommittee of the Advisory Committee on Commercial Operations of U.S. Customs and Border Protection (COAC) recommended at the Aug. 4 COAC meeting in Detroit that CBP provide the following benefits to importers that are highly compliant with ISF requirements.
• For importers who are certified Customs-Trade Partnership Against Terrorism members, high compliance with ISF requirements should be deemed a best practice and considered with respect to elevating the importer’s C-TPAT status to the Tier 3 level.
• In cases where stratified compliance exams are undertaken by CBP (where multiple shipments are under one bill of lading) and the importer is a C-TPAT member, CBP should allow sealed containers not being examined to not only move to destination but to be released by CBP.
• CBP should also consider the option of releasing for distribution other bills of lading on the same entry (where the importer is a C-TPAT member). As with the above recommendation, the released containers in question would be those not designated for exam. To address potential CBP concerns, this benefit would not include containers stuffed by the same party that stuffed the container(s) designated for exam.
• For small and medium-size importers that are highly compliant, CBP should consider a streamlined process for application to C-TPAT.
• In the case of unified ISF filings, conditional release in the system at time of vessel departure should be provided.
• Consideration of mitigation for other penalties (outside those associated with ISF compliance) should be given for highly compliant importers.
• For continuous, highly compliant importers, there may be a situation where CBP identifies a problem that is very low frequency (e.g., one out of a thousand). CBP should take this into consideration with respect to penalties.
The subcommittee also included information on the collateral benefits of ISF that have been identified by highly compliant importers. One such benefit is that importers have better visibility into their global supply chains since they now have a CBP process at origin. Companies can identify non-standard shipments earlier in the process, allowing them more time to address the issue prior to arrival and potential delay. In addition, because importers provide data earlier, there are fewer delays at destination. Working through the ISF requirements has also highlighted that import compliance teams need to be folded into the procurement process earlier. Finally, importers have become more engaged with parties not typically communicated with in the past, which provides more visibility and improvement in data availability and accuracy.
