Showing posts with label ISF. Show all posts
Showing posts with label ISF. Show all posts
Sunday, October 17, 2010
Thursday, October 14, 2010
10+2 Rule Scores 80% Compliance
(Journal of Commerce Online – R.G.Edmonson)
Nearly 1,000 unmanifested containers identified since January
Customs and Border Protection said 80 percent of importer filings comply with the Importer Security Filing, or 10+2 rule, since enforcement began in January. The agency also identified approximately 1,000 unmanifested containers from vessel stow plans that carriers file. Such containers present the highest security risk.
The findings were noted in a report Tuesday from the Government Accountability Office, which added the comment that Customs needs to integrate the data it collects into its overall targeting strategy. GAO also said that under White House Office of Management and Budget rules, Customs should be more transparent in assessing how it put the ISF rule into effect. Read more here.
Tuesday, August 10, 2010
CBP Urged to Provide Benefits for ISF Highly Compliant Importers
(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.
Wednesday, May 26, 2010
Reminder: CBP ISF/10-+2 Webinar
May 27, 2010 – Small to Medium Size Companies
U.S. Customs and Border Protection is holding another webinar to help the trade community understand how to comply with the Importer Security Filing and Additional Carrier requirements, commonly known as “10+2,” that went into effect January 26, 2010. CBP be hosting the webinar on Thursday May 27, 2010 from 2:00 to 3:00 PM (EDT), specifically focusing on the needs of small to medium-sized companies importing into the United States.
The one-hour webinar is primarily geared towards small and medium-sized importers who have limited familiarity with the Importer Security Filing and Additional Carrier Requirements.
The program will consist of a high-level overview of the “10+2” requirements, an update on the statistics and current trends, critical information on enforcement; and will conclude with a question and answer session. To register click here.
U.S. Customs and Border Protection is holding another webinar to help the trade community understand how to comply with the Importer Security Filing and Additional Carrier requirements, commonly known as “10+2,” that went into effect January 26, 2010. CBP be hosting the webinar on Thursday May 27, 2010 from 2:00 to 3:00 PM (EDT), specifically focusing on the needs of small to medium-sized companies importing into the United States.
The one-hour webinar is primarily geared towards small and medium-sized importers who have limited familiarity with the Importer Security Filing and Additional Carrier Requirements.
The program will consist of a high-level overview of the “10+2” requirements, an update on the statistics and current trends, critical information on enforcement; and will conclude with a question and answer session. To register click here.
Tuesday, May 4, 2010
DHS Lists Upcoming Regulatory Actions Affecting Importers, Brokers, Carriers
(World Trade Interactive)
The Department of Homeland Security recently issued its semiannual regulatory agenda, which includes the following actions affecting international trade.
• U.S. Customs and Border Protection has pushed back to July a proposed rule that would amend its regulations concerning cargo information (manifest) discrepancy reporting requirements for all modes of commercial transportation (air, sea, rail and truck).
This rule would:
(a) set forth corresponding guidelines for the assessment of penalties or claims for liquidated damages for manifesting violations;
(b) require that any discrepancy from previously filed cargo information be reported to CBP by the responsible party immediately upon discovery and that such reports, with limited exceptions, be submitted in an electronic format;
(c) eliminate Customs Form 5931 and require that cargo declaration information be kept for a period of five years after conveyance arrival; and
(d) provide guidelines for the assessment of penalties for failing to reporting discrepancies.
• In June CBP plans to issue a proposed rule amending its regulations pertaining to the obligations of customs brokers to keep clients’ information confidential.
• A CBP final rule removing the regulatory provisions pertaining to the Land Border Carrier Initiative Program is slated for June.
• By November CBP intends to finalize interim regulations issued in 2008 concerning the importer security filing, or 10+2, rule.
• CBP anticipates publishing by August a final rule establishing another international registered traveler program called Global Entry, which would provide an expedited inspection process for pre-approved, pre-screened travelers. A pilot of Global Entry has been operating since June 6, 2008.
• A CBP final rule amending the requirements an individual must satisfy to take the written examination for an individual customs broker’s license has been delayed until June.
• The Transportation Security Administration is still planning to issue by October a supplemental proposed rule concerning its security programs for large aircraft, other aircraft operators and airport operators. TSA is considering alternatives to provisions in its 2008 proposed rule concerning (a) the weight threshold for aircraft subject to TSA regulation, (b) compliance oversight, (c) watch list matching of passengers, (d) prohibited items, (e) scope of the background check requirements and the procedures used to implement the requirement, and (f) other issues.
• TSA expects to finalize by November interim final regulations issued in September 2009 concerning the Certified Cargo Screening Program. The CCSP will certify shippers, manufacturers and other entities to screen air cargo intended for transport on a passenger aircraft and will be the primary means through which TSA will meet the statutory requirement that 100% of air cargo transported on passenger aircraft, operated by an air carrier or foreign air carrier in air transportation or intrastate air transportation, must be screened by August 2010.
The Department of Homeland Security recently issued its semiannual regulatory agenda, which includes the following actions affecting international trade.
• U.S. Customs and Border Protection has pushed back to July a proposed rule that would amend its regulations concerning cargo information (manifest) discrepancy reporting requirements for all modes of commercial transportation (air, sea, rail and truck).
This rule would:
(a) set forth corresponding guidelines for the assessment of penalties or claims for liquidated damages for manifesting violations;
(b) require that any discrepancy from previously filed cargo information be reported to CBP by the responsible party immediately upon discovery and that such reports, with limited exceptions, be submitted in an electronic format;
(c) eliminate Customs Form 5931 and require that cargo declaration information be kept for a period of five years after conveyance arrival; and
(d) provide guidelines for the assessment of penalties for failing to reporting discrepancies.
• In June CBP plans to issue a proposed rule amending its regulations pertaining to the obligations of customs brokers to keep clients’ information confidential.
• A CBP final rule removing the regulatory provisions pertaining to the Land Border Carrier Initiative Program is slated for June.
• By November CBP intends to finalize interim regulations issued in 2008 concerning the importer security filing, or 10+2, rule.
• CBP anticipates publishing by August a final rule establishing another international registered traveler program called Global Entry, which would provide an expedited inspection process for pre-approved, pre-screened travelers. A pilot of Global Entry has been operating since June 6, 2008.
• A CBP final rule amending the requirements an individual must satisfy to take the written examination for an individual customs broker’s license has been delayed until June.
• The Transportation Security Administration is still planning to issue by October a supplemental proposed rule concerning its security programs for large aircraft, other aircraft operators and airport operators. TSA is considering alternatives to provisions in its 2008 proposed rule concerning (a) the weight threshold for aircraft subject to TSA regulation, (b) compliance oversight, (c) watch list matching of passengers, (d) prohibited items, (e) scope of the background check requirements and the procedures used to implement the requirement, and (f) other issues.
• TSA expects to finalize by November interim final regulations issued in September 2009 concerning the Certified Cargo Screening Program. The CCSP will certify shippers, manufacturers and other entities to screen air cargo intended for transport on a passenger aircraft and will be the primary means through which TSA will meet the statutory requirement that 100% of air cargo transported on passenger aircraft, operated by an air carrier or foreign air carrier in air transportation or intrastate air transportation, must be screened by August 2010.
Friday, March 12, 2010
U.S. Customs Faces 10+2 Confusion
(Journal of Commerce – Peter T. Leach)
Agency reaching out to importers to explain the rules
With the new Importer Security Filing rule still in its shakedown period, Customs and Border Protection is trying to help importers figure out the rule and its own responses to application of the rule, known as 10+2 because of the 10 security data elements the agency now requires from importers and two from carriers 24 hours before a U.S.-bound container is loaded aboard a ship.
Richard DiNucci, director of the Secure Freight Initiative, told the annual Northeast Trade and Transportation Conference here Thursday the weekly filings of the 10+2 data have increased by 25% since the start of the rule on Jan. 26.
“About 70% to 80% of importers are filing, and some ports are 95% to 100% compliant,” he said. He said CBP is continuing to reach out to importers to explain the rules. He said that CBP will send out warning letters “shortly” to importers that are not in compliance with the rule but “will not penalize importers who have failed.” Read more here.
Agency reaching out to importers to explain the rules
With the new Importer Security Filing rule still in its shakedown period, Customs and Border Protection is trying to help importers figure out the rule and its own responses to application of the rule, known as 10+2 because of the 10 security data elements the agency now requires from importers and two from carriers 24 hours before a U.S.-bound container is loaded aboard a ship.
Richard DiNucci, director of the Secure Freight Initiative, told the annual Northeast Trade and Transportation Conference here Thursday the weekly filings of the 10+2 data have increased by 25% since the start of the rule on Jan. 26.
“About 70% to 80% of importers are filing, and some ports are 95% to 100% compliant,” he said. He said CBP is continuing to reach out to importers to explain the rules. He said that CBP will send out warning letters “shortly” to importers that are not in compliance with the rule but “will not penalize importers who have failed.” Read more here.
Monday, February 8, 2010
Customs Adding Up 10+2
(Journal of Commerce Online – R.G.Edmonson)
Penalties won’t start for months, but the agency isn’t waiting to notify violators
For importers still in denial about the Importer Security Filing rule, Customs and Border Protection has a message: “We’re not delaying enforcement. What you submit or don’t submit is going to be held against you,” said Richard DiNucci, director of the Secure Freight Initiative.
Customs began enforcing the rule – known as 10+2 because of the 10 security data elements the agency now requires from importers and two from carriers 24 hours before a U.S.-bound container is loaded aboard a ship – on January 26, but because the agency is still two or three months from imposing penalties, some traders don’t believe it’s happening, DiNucci said.
True, Customs won’t be assessing liquidated damages – fines of $5,000 per violation, before mitigation – until the second or third quarter. But it’s tallying ISF violations to build its case for taking tougher measures.
“We review the data. If you’re consistently missing a data element, you will get a notice from us that the data isn’t included or it is inaccurate. Or if you’re consistently late, we’ll tell you to clean it up,” DiNucci said. Read more here.
Penalties won’t start for months, but the agency isn’t waiting to notify violators
For importers still in denial about the Importer Security Filing rule, Customs and Border Protection has a message: “We’re not delaying enforcement. What you submit or don’t submit is going to be held against you,” said Richard DiNucci, director of the Secure Freight Initiative.
Customs began enforcing the rule – known as 10+2 because of the 10 security data elements the agency now requires from importers and two from carriers 24 hours before a U.S.-bound container is loaded aboard a ship – on January 26, but because the agency is still two or three months from imposing penalties, some traders don’t believe it’s happening, DiNucci said.
True, Customs won’t be assessing liquidated damages – fines of $5,000 per violation, before mitigation – until the second or third quarter. But it’s tallying ISF violations to build its case for taking tougher measures.
“We review the data. If you’re consistently missing a data element, you will get a notice from us that the data isn’t included or it is inaccurate. Or if you’re consistently late, we’ll tell you to clean it up,” DiNucci said. Read more here.
Tuesday, February 2, 2010
Updated ISF 10+2 FAQs
(CBP)
An updated version of the 10+2 FAQs have been posted to our website. The most recent changes have been highlighted for your convenience.
This version of the FAQs can be found on the Security Filing 10+2 page here.
An updated version of the 10+2 FAQs have been posted to our website. The most recent changes have been highlighted for your convenience.
This version of the FAQs can be found on the Security Filing 10+2 page here.
Thursday, December 10, 2009
Ahern Promises Phased ‘10+2’ Enforcement
(CSCB – American Shipper)
The following is excerpted from the 9 December 2009 edition of “American Shipper”
U.S. Customs and Border Protection will not use a heavy hand to enforce the Importer Security Filing when the agency lifts its moratorium on issuing penalties for the advance commercial data requirements early next year, Acting Commissioner Jayson Ahern assured more than 800 import-export professionals on Tuesday.
The rule went into effect on January 26 and CBP gave importers and their logistics service providers a year to adapt their systems and processes before beginning enforcement measures.
Under ISF, importers must electronically submit 10 types of information identifying partners and locations responsible for moving a shipment via an ocean container from an overseas manufacturing site to a U.S. receiver – and do so 24 hours prior to vessel loading. Ocean carriers are to provide two sets of data related to their handling of the container.
The import community has faced enormous challenges preparing for the “10+2” rule, most notably tracing back the information to various suppliers, investing in systems to collect the data earlier than ever before and transmitting it to CBP through an approved information pipeline. Read more here.
The following is excerpted from the 9 December 2009 edition of “American Shipper”
U.S. Customs and Border Protection will not use a heavy hand to enforce the Importer Security Filing when the agency lifts its moratorium on issuing penalties for the advance commercial data requirements early next year, Acting Commissioner Jayson Ahern assured more than 800 import-export professionals on Tuesday.
The rule went into effect on January 26 and CBP gave importers and their logistics service providers a year to adapt their systems and processes before beginning enforcement measures.
Under ISF, importers must electronically submit 10 types of information identifying partners and locations responsible for moving a shipment via an ocean container from an overseas manufacturing site to a U.S. receiver – and do so 24 hours prior to vessel loading. Ocean carriers are to provide two sets of data related to their handling of the container.
The import community has faced enormous challenges preparing for the “10+2” rule, most notably tracing back the information to various suppliers, investing in systems to collect the data earlier than ever before and transmitting it to CBP through an approved information pipeline. Read more here.
Tuesday, November 10, 2009
CBP Official Outlines Policy on Enforcement of Importer Security Filing Rule
(The Perishable Specialist)
According to press reports, Assistant Commissioner Thomas Winkowski told a November 4 meeting of the Commercial Operations Advisory Committee that U.S. Customs and Border Protection will “take a common sense approach” to imposing penalties for violating the 10+2 importer security filing rule once the current period of informed compliance ends January 26, 2010. Winkowski assured the trade community that CBP’s focus will be more on aiding compliance with the rule than penalizing minor violations and stated that as a result all ISF penalties will first be reviewed at CBP headquarters.
Under the ISF rule, importers and maritime cargo carriers must submit additional cargo data to CBP before vessels are permitted entry into the country. Importers have to report 10 data elements on each ISF, including information that identifies the manufacturer, supplier, seller, buyer and consignee; the country of origin and tariff classification number; where and by whom the goods were stuffed into the container; and the party responsible for compliance with applicable import requirements. Five data elements are required for shipments consisting entirely of freight remaining on board cargo or goods intended to be transported in-bond as an immediate entry or transportation and exportation entry, including who is paying for the transportation of the goods and where the goods are headed. CBP’s goal is to have all data elements filed 24 hours prior to lading, but it has allowed for some flexibility either in timing or interpretation for six of the data elements.
The ISF rule took effect January 26, 2009, but full enforcement will not take effect until January 26, 2010, following a year of education, outreach and informed compliance efforts. As of that date, importers will be subject to fines of $5,000 each time an ISF filing is late or inaccurate. At the recent COAC meeting, however, Winkowski said “it’s not about penalties” or “nitpicking” for CBP, which will seek to avoid levying penalties for minor ISF filing mistakes and instead continue efforts to inform filers of the rule’s requirements. Those efforts have thus far included the issuance of ISF penalty mitigation guidelines and the posting of a list of answers to frequently asked questions on the CBP Web site, and Winkowski said enforcement guidelines are also being developed.
According to press reports, Assistant Commissioner Thomas Winkowski told a November 4 meeting of the Commercial Operations Advisory Committee that U.S. Customs and Border Protection will “take a common sense approach” to imposing penalties for violating the 10+2 importer security filing rule once the current period of informed compliance ends January 26, 2010. Winkowski assured the trade community that CBP’s focus will be more on aiding compliance with the rule than penalizing minor violations and stated that as a result all ISF penalties will first be reviewed at CBP headquarters.
Under the ISF rule, importers and maritime cargo carriers must submit additional cargo data to CBP before vessels are permitted entry into the country. Importers have to report 10 data elements on each ISF, including information that identifies the manufacturer, supplier, seller, buyer and consignee; the country of origin and tariff classification number; where and by whom the goods were stuffed into the container; and the party responsible for compliance with applicable import requirements. Five data elements are required for shipments consisting entirely of freight remaining on board cargo or goods intended to be transported in-bond as an immediate entry or transportation and exportation entry, including who is paying for the transportation of the goods and where the goods are headed. CBP’s goal is to have all data elements filed 24 hours prior to lading, but it has allowed for some flexibility either in timing or interpretation for six of the data elements.
The ISF rule took effect January 26, 2009, but full enforcement will not take effect until January 26, 2010, following a year of education, outreach and informed compliance efforts. As of that date, importers will be subject to fines of $5,000 each time an ISF filing is late or inaccurate. At the recent COAC meeting, however, Winkowski said “it’s not about penalties” or “nitpicking” for CBP, which will seek to avoid levying penalties for minor ISF filing mistakes and instead continue efforts to inform filers of the rule’s requirements. Those efforts have thus far included the issuance of ISF penalty mitigation guidelines and the posting of a list of answers to frequently asked questions on the CBP Web site, and Winkowski said enforcement guidelines are also being developed.
Tuesday, September 15, 2009
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.
[Source and website]
Note: The foregoing is presented for information purposes only. GHY International does not necessarily endorse or recommend the product(s) referenced in this article.
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.
[Source and website]
Note: The foregoing is presented for information purposes only. GHY International does not necessarily endorse or recommend the product(s) referenced in this article.
Tuesday, September 1, 2009
Compliance Failures Could Cost U.S. Importers Dearly in 2010
(eyefortransport – Matt Gersper, Global Data Mining)
Failure to comply with the Importer Security Filing (ISF) regulations could cause delays and fines that spell financial disaster for unprepared US businesses, says Matt Gersper, founder & president of Global Data Mining.
Gersper says there are three major reasons why business leaders should make sure that their companies are compliant, and each reason has a direct bottom-line impact.
• The risk of significant penalties for non-compliance: According to the ISF regulations, commonly referred to as 10+2, effective January 26 next year, an importer can be fined $5,000 per filing if an ISF is late, incomplete or inaccurate, and up to $10,000 per filing for two or more violations.
• Custom & Border Protection’s (CBP’s) renewed commitment to trade law enforcement and accurate revenue collection, which is the U.S. government’s No.2 strategic goal – ahead of improving national and economic security.
• The impact of supply chain delays: according to a recent study by the National Association of Manufacturers (NAM), the ISF regulation will create a permanent 2.8 day delay in supply chain speed.
Research into the current state of ISF compliance and the impact this regulation has (and will have) on the supply chain reveals that:
• Providing timely ISF data is a challenge for nearly 60% of companies
• Collecting complete ISF data is a struggle for nearly 40%
• Around 20% have problems with the accuracy of the data they provide
These are the very three issues causing penalties to be assessed. Read more here.
Failure to comply with the Importer Security Filing (ISF) regulations could cause delays and fines that spell financial disaster for unprepared US businesses, says Matt Gersper, founder & president of Global Data Mining.
Gersper says there are three major reasons why business leaders should make sure that their companies are compliant, and each reason has a direct bottom-line impact.
• The risk of significant penalties for non-compliance: According to the ISF regulations, commonly referred to as 10+2, effective January 26 next year, an importer can be fined $5,000 per filing if an ISF is late, incomplete or inaccurate, and up to $10,000 per filing for two or more violations.
• Custom & Border Protection’s (CBP’s) renewed commitment to trade law enforcement and accurate revenue collection, which is the U.S. government’s No.2 strategic goal – ahead of improving national and economic security.
• The impact of supply chain delays: according to a recent study by the National Association of Manufacturers (NAM), the ISF regulation will create a permanent 2.8 day delay in supply chain speed.
Research into the current state of ISF compliance and the impact this regulation has (and will have) on the supply chain reveals that:
• Providing timely ISF data is a challenge for nearly 60% of companies
• Collecting complete ISF data is a struggle for nearly 40%
• Around 20% have problems with the accuracy of the data they provide
These are the very three issues causing penalties to be assessed. Read more here.
Monday, July 20, 2009
Guidelines on Liquidated Damages for Importer Security Filing Violations
(CBP via World Trade Interactive)
U.S. Customs and Border Protection issued in the July 17, 2009, Customs Bulletin and Decisions a general notice setting forth guidelines on the assessment and cancellation of claims for liquidated damages incurred by importers and vessel carriers for failure to comply with the importer security filing (10+2) rule.
Under the ISF rule importers are required to submit ten additional data elements for shipments entering the U.S., including information that identifies the manufacturer, supplier, seller, buyer and consignee; the country of origin and tariff classification number; where and by whom the goods were stuffed into the container; and the party responsible for compliance with applicable import requirements. In addition, carriers are generally required to submit two additional data elements for containers loaded on vessels destined to the U.S., a vessel stow plan and container status messages.
Importer Security Filing – Failure to File
• Liquidated damages cannot be assessed for failure to file an ISF if no bond is in place.
• If goods for which an ISF has not been filed arrive in the U.S., CBP will withhold the release or transfer of the cargo until it receives the required ISF information and has had the opportunity to review the documentation and conduct any necessary examination.
• CBP reserves the right to limit the permit to unlade so as to not permit unlading of merchandise for which no ISF has been filed. If such cargo is unladen without permission, it may be subject to seizure. All seizures will be approved by CBP headquarters.
Importer Security Filing – Late or Inaccurate Filing
• Port directors may assess claims for liquidated damages in the amount of $5,000 per ISF for (a) late filed ISFs, (b) inaccurate ISFs or ISF updates, and (c) failure to withdraw an ISF when required. Penalties may be assessed, with CBP headquarters approval, for serious or repetitive violations.
• Liquidated damages claims for late ISFs or inaccurate ISFs or ISF updates may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon payment of (a) between $1,000 and $2,000 (depending on the presence of mitigating or aggravating factors) for the first violation and (b) not less than $2,500 for subsequent violations.
• Mitigating factors include evidence of progress in implementing the ISF requirement during the flexible enforcement period (i.e., Jan. 26, 2009, through Jan. 26, 2010), small number of violations compared to the number of shipments for which ISFs were required, certification as Tier 2 or Tier 3 member of the Customs-Trade Partnership Against Terrorism, demonstrated remedial action to prevent future violations, and vessel diversion due to factors outside the ISF importer’s control. For inaccurate filings, if the importer acquired information from another party in accordance with ordinary commercial practices and can demonstrate that it reasonably believed the information to be true and was not reasonably able to verify the information, this will be considered an extraordinary mitigating factor that may warrant cancellation of a claim without payment.
• Aggravating factors include lack of cooperation with CBP or impeding CBP activity with regard to the case, evidence of actual or attempted smuggling (this may be considered an extraordinary aggravating factor), multiple errors on the ISF, and a rising error rate indicative of deteriorating performance
Vessel Stow Plans
• When a carrier arrives at a port of entry where a vessel stow plan is required, port directors may assess a claim for liquidated damages against the carrier in the amount of $50,000 per plan when a complete, accurate and timely plan is not submitted. A claim for liquidated damages in the amount of $50,000 may be assessed for each vessel arrival. Penalties may be assessed, with CBP headquarters approval, for serious or repetitive violations.
• For failure to file, liquidated damages claims may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon the payment of (a) between $5,000 and $25,000 (depending on the presence of mitigating or aggravating factors) for a first violation and (b) $25,000 for subsequent violations.
• For late and inaccurate filings, liquidated damages claims may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon the payment of (a) between $2,500 and $10,000 (depending on the presence of mitigating or aggravating factors) for a first violation and (b) not less than $5,000 for subsequent violations.
• Mitigating factors include evidence of progress in the implementation of the vessel stow plan requirement during the flexible enforcement period, vessel diversion due to factors outside of the carrier’s control, validation and good standing in C-TPAT, and demonstrated remedial action to prevent future violations. Demonstrating that the carrier acquired the information from another party in accordance with ordinary commercial practices, reasonably believed this information to be true and was not reasonably able to verify the information is an extraordinary mitigating factor that may warrant cancellation of a claim without payment.
• Aggravating factors include lack of cooperation with CBP or impeding CBP activity with regard to the case, evidence of actual or attempted smuggling (this may be considered an extraordinary aggravating factor), multiple errors on the vessel stow plan, and a rising error rate indicative of deteriorating performance.
Container Status Messages
• Port directors may assess claims for liquidated damages against carriers in the amount of $5,000 per CSM for failing to submit a CSM, late filing a CSM, or submitting an inaccurate CSM. Such claims may be assessed up to a maximum of $100,000 per vessel arrival. Penalties may be assessed for serious or repetitive violations.
• For failure to file, liquidated damages claims may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon the payment of (a) between $1,000 and $2,000 (depending on the presence of mitigating or aggravating factors) for a first violation and (b) $2,500 for subsequent violations.
• For late and inaccurate filings, liquidated damages claims may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon the payment of (a) between $500 and $1,000 (depending on the presence of mitigating or aggravating factors) for a first violation and (b) not less than $1,500 for subsequent violations.
• Mitigating factors will include evidence of progress in the implementation of the CSM requirement during the flexible enforcement period, small number of violations compared to the number of CSMs submitted, validation and good standing in C-TPAT, and demonstrated remedial action to prevent future violations. Demonstrating that the carrier acquired the information from another party in accordance with ordinary commercial practices, reasonably believed this information to be true and was not reasonably able to verify the information is an extraordinary mitigating factor that may warrant cancellation of a claim without payment.
• Aggravating factors include lack of cooperation with CBP or impeding CBP activity with regard to the case, evidence of actual or attempted smuggling (this may be considered an extraordinary aggravating factor), multiple errors on the CSM, and a rising error rate indicative of deteriorating performance.
Other Penalties
CBP states that in addition to liquidated damages that may be assessed as provided above, the failure of an arriving carrier or ISF importer to provide the required advance electronic cargo information in the time period and manner prescribed may result in the issuance of a do not load hold, the delay or denial of a vessel carrier’s preliminary entry permit/special license to unlade and/or the assessment of any other applicable statutory penalty. CBP may also withhold the release or transfer of the cargo until it receives the required information and has had the opportunity to review the documentation and conduct any necessary examination.
U.S. Customs and Border Protection issued in the July 17, 2009, Customs Bulletin and Decisions a general notice setting forth guidelines on the assessment and cancellation of claims for liquidated damages incurred by importers and vessel carriers for failure to comply with the importer security filing (10+2) rule.
Under the ISF rule importers are required to submit ten additional data elements for shipments entering the U.S., including information that identifies the manufacturer, supplier, seller, buyer and consignee; the country of origin and tariff classification number; where and by whom the goods were stuffed into the container; and the party responsible for compliance with applicable import requirements. In addition, carriers are generally required to submit two additional data elements for containers loaded on vessels destined to the U.S., a vessel stow plan and container status messages.
Importer Security Filing – Failure to File
• Liquidated damages cannot be assessed for failure to file an ISF if no bond is in place.
• If goods for which an ISF has not been filed arrive in the U.S., CBP will withhold the release or transfer of the cargo until it receives the required ISF information and has had the opportunity to review the documentation and conduct any necessary examination.
• CBP reserves the right to limit the permit to unlade so as to not permit unlading of merchandise for which no ISF has been filed. If such cargo is unladen without permission, it may be subject to seizure. All seizures will be approved by CBP headquarters.
Importer Security Filing – Late or Inaccurate Filing
• Port directors may assess claims for liquidated damages in the amount of $5,000 per ISF for (a) late filed ISFs, (b) inaccurate ISFs or ISF updates, and (c) failure to withdraw an ISF when required. Penalties may be assessed, with CBP headquarters approval, for serious or repetitive violations.
• Liquidated damages claims for late ISFs or inaccurate ISFs or ISF updates may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon payment of (a) between $1,000 and $2,000 (depending on the presence of mitigating or aggravating factors) for the first violation and (b) not less than $2,500 for subsequent violations.
• Mitigating factors include evidence of progress in implementing the ISF requirement during the flexible enforcement period (i.e., Jan. 26, 2009, through Jan. 26, 2010), small number of violations compared to the number of shipments for which ISFs were required, certification as Tier 2 or Tier 3 member of the Customs-Trade Partnership Against Terrorism, demonstrated remedial action to prevent future violations, and vessel diversion due to factors outside the ISF importer’s control. For inaccurate filings, if the importer acquired information from another party in accordance with ordinary commercial practices and can demonstrate that it reasonably believed the information to be true and was not reasonably able to verify the information, this will be considered an extraordinary mitigating factor that may warrant cancellation of a claim without payment.
• Aggravating factors include lack of cooperation with CBP or impeding CBP activity with regard to the case, evidence of actual or attempted smuggling (this may be considered an extraordinary aggravating factor), multiple errors on the ISF, and a rising error rate indicative of deteriorating performance
Vessel Stow Plans
• When a carrier arrives at a port of entry where a vessel stow plan is required, port directors may assess a claim for liquidated damages against the carrier in the amount of $50,000 per plan when a complete, accurate and timely plan is not submitted. A claim for liquidated damages in the amount of $50,000 may be assessed for each vessel arrival. Penalties may be assessed, with CBP headquarters approval, for serious or repetitive violations.
• For failure to file, liquidated damages claims may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon the payment of (a) between $5,000 and $25,000 (depending on the presence of mitigating or aggravating factors) for a first violation and (b) $25,000 for subsequent violations.
• For late and inaccurate filings, liquidated damages claims may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon the payment of (a) between $2,500 and $10,000 (depending on the presence of mitigating or aggravating factors) for a first violation and (b) not less than $5,000 for subsequent violations.
• Mitigating factors include evidence of progress in the implementation of the vessel stow plan requirement during the flexible enforcement period, vessel diversion due to factors outside of the carrier’s control, validation and good standing in C-TPAT, and demonstrated remedial action to prevent future violations. Demonstrating that the carrier acquired the information from another party in accordance with ordinary commercial practices, reasonably believed this information to be true and was not reasonably able to verify the information is an extraordinary mitigating factor that may warrant cancellation of a claim without payment.
• Aggravating factors include lack of cooperation with CBP or impeding CBP activity with regard to the case, evidence of actual or attempted smuggling (this may be considered an extraordinary aggravating factor), multiple errors on the vessel stow plan, and a rising error rate indicative of deteriorating performance.
Container Status Messages
• Port directors may assess claims for liquidated damages against carriers in the amount of $5,000 per CSM for failing to submit a CSM, late filing a CSM, or submitting an inaccurate CSM. Such claims may be assessed up to a maximum of $100,000 per vessel arrival. Penalties may be assessed for serious or repetitive violations.
• For failure to file, liquidated damages claims may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon the payment of (a) between $1,000 and $2,000 (depending on the presence of mitigating or aggravating factors) for a first violation and (b) $2,500 for subsequent violations.
• For late and inaccurate filings, liquidated damages claims may be canceled, provided CBP determines that law enforcement goals were not compromised by the violation, upon the payment of (a) between $500 and $1,000 (depending on the presence of mitigating or aggravating factors) for a first violation and (b) not less than $1,500 for subsequent violations.
• Mitigating factors will include evidence of progress in the implementation of the CSM requirement during the flexible enforcement period, small number of violations compared to the number of CSMs submitted, validation and good standing in C-TPAT, and demonstrated remedial action to prevent future violations. Demonstrating that the carrier acquired the information from another party in accordance with ordinary commercial practices, reasonably believed this information to be true and was not reasonably able to verify the information is an extraordinary mitigating factor that may warrant cancellation of a claim without payment.
• Aggravating factors include lack of cooperation with CBP or impeding CBP activity with regard to the case, evidence of actual or attempted smuggling (this may be considered an extraordinary aggravating factor), multiple errors on the CSM, and a rising error rate indicative of deteriorating performance.
Other Penalties
CBP states that in addition to liquidated damages that may be assessed as provided above, the failure of an arriving carrier or ISF importer to provide the required advance electronic cargo information in the time period and manner prescribed may result in the issuance of a do not load hold, the delay or denial of a vessel carrier’s preliminary entry permit/special license to unlade and/or the assessment of any other applicable statutory penalty. CBP may also withhold the release or transfer of the cargo until it receives the required information and has had the opportunity to review the documentation and conduct any necessary examination.
Tuesday, July 14, 2009
CBP Amends Interim Final Rule on Importer Security Filing
(World Trade Interactive)
U.S. Customs and Border Protection has made several amendments to its Nov. 25, 2008, interim final rule concerning the importer security filing (10+2). CBP states that because the rule’s regulatory text was inadvertently silent regarding the time frame for transmitting an ISF for shipments intended to be transported in-bond for immediate exportation or transportation and exportation, this text is now being revised to clarify that the appropriate data elements must be submitted no later than 24 hours before the cargo is laden aboard the vessel at the foreign port.
CBP is also correcting its responses to two comments in the preamble text to align them with the regulatory text. One correction clarifies that carriers are only obligated to transmit container status messages for events that occur prior to first arrival of the goods at a U.S. port. The second indicates that the ISF must be updated if there is a change before the goods enter the limits of the first port of arrival in the U.S. and that amendments to the ISF will be accepted at any time after the goods arrive in a U.S. port.
U.S. Customs and Border Protection has made several amendments to its Nov. 25, 2008, interim final rule concerning the importer security filing (10+2). CBP states that because the rule’s regulatory text was inadvertently silent regarding the time frame for transmitting an ISF for shipments intended to be transported in-bond for immediate exportation or transportation and exportation, this text is now being revised to clarify that the appropriate data elements must be submitted no later than 24 hours before the cargo is laden aboard the vessel at the foreign port.
CBP is also correcting its responses to two comments in the preamble text to align them with the regulatory text. One correction clarifies that carriers are only obligated to transmit container status messages for events that occur prior to first arrival of the goods at a U.S. port. The second indicates that the ISF must be updated if there is a change before the goods enter the limits of the first port of arrival in the U.S. and that amendments to the ISF will be accepted at any time after the goods arrive in a U.S. port.
Monday, June 29, 2009
Automated Broker Interface: Implementation Delay – Pending ISF Transaction Sets
(CBP)
On June 19, 2009, CSMS #09-000249 was issued announcing that pending changes to the Importer Security Filing (ISF) Transaction Sets for ABI and AMS will be implemented on July 1, 2009. Those changes will NOT be implemented on July 1; instead, they will be implemented on Sunday morning July 12, 2009 during the scheduled ACS maintenance window that extends to 03:00am Eastern Time. Again, the changes will become available in both the Production and the Certification regions at the conclusion of that maintenance window.
The pending Transaction Sets as well as a list of the specific changes can be found here.
On June 19, 2009, CSMS #09-000249 was issued announcing that pending changes to the Importer Security Filing (ISF) Transaction Sets for ABI and AMS will be implemented on July 1, 2009. Those changes will NOT be implemented on July 1; instead, they will be implemented on Sunday morning July 12, 2009 during the scheduled ACS maintenance window that extends to 03:00am Eastern Time. Again, the changes will become available in both the Production and the Certification regions at the conclusion of that maintenance window.
The pending Transaction Sets as well as a list of the specific changes can be found here.
Friday, June 19, 2009
Manufacturers Say 10+2 Costs $20 Billion
(Journal of Commerce Online – Alan Field)
Manufacturers say operations, delays to double cost of tariffs
U.S. Customs and Border Protection’s Importer Security Filing rule will impose an annual cost of more than $20 billion on the U.S. economy, according to a study by a manufacturers’ group. The “10+2” rule will require manufacturers and other importers to provide expensive new data to the government, says a report by the Customs and Border Coalition, a group launched by the National Association of Manufacturers in December.
Based on a survey of companies accounting for nearly 60% of seaborne manufactured imports, the survey corroborates an earlier report issued by the NAM, said NAM President John Engler. “The potential impact of this rule is huge,” Engler said. “To put the cost in perspective, it is virtually the equivalent of doubling the import tariffs that manufacturers now pay to bring products and components into the United States.” Read more here.
Manufacturers say operations, delays to double cost of tariffs
U.S. Customs and Border Protection’s Importer Security Filing rule will impose an annual cost of more than $20 billion on the U.S. economy, according to a study by a manufacturers’ group. The “10+2” rule will require manufacturers and other importers to provide expensive new data to the government, says a report by the Customs and Border Coalition, a group launched by the National Association of Manufacturers in December.
Based on a survey of companies accounting for nearly 60% of seaborne manufactured imports, the survey corroborates an earlier report issued by the NAM, said NAM President John Engler. “The potential impact of this rule is huge,” Engler said. “To put the cost in perspective, it is virtually the equivalent of doubling the import tariffs that manufacturers now pay to bring products and components into the United States.” Read more here.
Tuesday, May 26, 2009
AAEI Says 10+2 Costs Will Mount
(American Shipper)
The American Association of Exporters and Importers [AAEI] in comments filed last week urged caution over the costs of U.S. Customs’ Importer Security Filing interim final rule.
ISF, also known as ‘10+2’, requires cargo information to be transmitted to CBP agents at least 24 hours before goods are shipped to the United States.
“AAEI expressed concern to U.S. Customs and Border Protection that the costs of ‘10+2’ compliance are still unknown,” the association said. “In the first months of implementation, the only cost CBP is capturing is the transaction fee for filing. However, AAEI notes that the true costs are much higher, especially for small and medium-sized enterprises. Plus, hidden costs of ‘10+2’ compliance will add up quickly due to delays and slowdowns in the supply chain.
“AAEI is also concerned about the lack of tangible benefits for voluntary participation in the costly C-TPAT program…” Read more here (subscription required).
The American Association of Exporters and Importers [AAEI] in comments filed last week urged caution over the costs of U.S. Customs’ Importer Security Filing interim final rule.
ISF, also known as ‘10+2’, requires cargo information to be transmitted to CBP agents at least 24 hours before goods are shipped to the United States.
“AAEI expressed concern to U.S. Customs and Border Protection that the costs of ‘10+2’ compliance are still unknown,” the association said. “In the first months of implementation, the only cost CBP is capturing is the transaction fee for filing. However, AAEI notes that the true costs are much higher, especially for small and medium-sized enterprises. Plus, hidden costs of ‘10+2’ compliance will add up quickly due to delays and slowdowns in the supply chain.
“AAEI is also concerned about the lack of tangible benefits for voluntary participation in the costly C-TPAT program…” Read more here (subscription required).
Friday, May 8, 2009
C-TPAT Members to Get “10+2” Report Cards
(American Shipper)
U.S. Customs and Border Protection will issue the first “10+2” progress reports on May 10 to let importers and their agents know how well they are complying with the rule for submitting advance electronic data about their cargo shipments, Assistant Commissioner Thomas Winkowski announced Wednesday.
The report cards will be sent by e-mail to all parties that have submitted Importer Security Filings (ISF) for their ocean shipments since the rule went into effect on Jan. 26.
CBP originally intended to send the progress reports only to filers, which will then be responsible for separating the individual spreadsheets and sending them on to their various customers. Most importers are using third-party vendors, such as customs brokers, forwarders and compliance software providers, to file on their behalf.
In a new twist, the border agency will also begin issuing report cards directly to all importers that participate in the Customs-Trade Partnership Against Terrorism, Winkowski told the 20 industry representatives on the Commercial Operations Advisory Committee meeting in Washington. Read more here (subscription required).
U.S. Customs and Border Protection will issue the first “10+2” progress reports on May 10 to let importers and their agents know how well they are complying with the rule for submitting advance electronic data about their cargo shipments, Assistant Commissioner Thomas Winkowski announced Wednesday.
The report cards will be sent by e-mail to all parties that have submitted Importer Security Filings (ISF) for their ocean shipments since the rule went into effect on Jan. 26.
CBP originally intended to send the progress reports only to filers, which will then be responsible for separating the individual spreadsheets and sending them on to their various customers. Most importers are using third-party vendors, such as customs brokers, forwarders and compliance software providers, to file on their behalf.
In a new twist, the border agency will also begin issuing report cards directly to all importers that participate in the Customs-Trade Partnership Against Terrorism, Winkowski told the 20 industry representatives on the Commercial Operations Advisory Committee meeting in Washington. Read more here (subscription required).
Friday, May 1, 2009
CBP to Adjust “10+2” Filing Logs, Deadline Intact
(American Shipper – Eric Kulisch)
U.S. Customs and Border Protection is changing the benchmark for measuring the timeliness of filing advance electronic data under the new “10+2” rule for imports, but the compliance deadline remain the same, the agency’s program manager emphasized Thursday.
About 45% of Importer Security Filings (ISF) are being submitted on time, but CBP believes that figure is low because it has been measuring timeliness against the time the first bill of lading is filed by the carrier under the 24-hour advance manifest rule. Many bills of lading are filed up to three days prior to vessel lading, which makes it difficult for importers to compile and file the necessary cargo details without demerit. Under the current system, the filing could be on time but appear late to CBP using the manifest as a back check. Read more here.
U.S. Customs and Border Protection is changing the benchmark for measuring the timeliness of filing advance electronic data under the new “10+2” rule for imports, but the compliance deadline remain the same, the agency’s program manager emphasized Thursday.
About 45% of Importer Security Filings (ISF) are being submitted on time, but CBP believes that figure is low because it has been measuring timeliness against the time the first bill of lading is filed by the carrier under the 24-hour advance manifest rule. Many bills of lading are filed up to three days prior to vessel lading, which makes it difficult for importers to compile and file the necessary cargo details without demerit. Under the current system, the filing could be on time but appear late to CBP using the manifest as a back check. Read more here.
Tuesday, April 14, 2009
How 10+2 Can Be Put to Real Use
(Journal of Commerce – Peter Tirschwell)
Implementing 10+2 may be a costly hassle for many importers, but for many it will reveal data about their supply chains that until now had been beyond their reach. For example, the requirement that the factory be included on the 10+2/ISF filing means that the importer will always know, assuming it obtains accurate data, which factories are making its merchandise at any given time and which service providers it is using for transportation.
John Motley, the CEO of Log-Net, sees a lot of opportunity here. For example, knowing where a factory is located, an importer might decide as part of a green initiative to use the closest port rather than one further away that is chosen by a carrier or intermediary. Read more here.
Implementing 10+2 may be a costly hassle for many importers, but for many it will reveal data about their supply chains that until now had been beyond their reach. For example, the requirement that the factory be included on the 10+2/ISF filing means that the importer will always know, assuming it obtains accurate data, which factories are making its merchandise at any given time and which service providers it is using for transportation.
John Motley, the CEO of Log-Net, sees a lot of opportunity here. For example, knowing where a factory is located, an importer might decide as part of a green initiative to use the closest port rather than one further away that is chosen by a carrier or intermediary. Read more here.
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