Importer Security Filing and "10+2"

I recently noticed that I have a “follower” on this blog from a company called TRG Direct which assists importers with various customs entry issues, including the filing of mandatory information with US Customs such as ISF filings.

Nearly one year ago US Customs began requiring advance notice of incoming cargo arriving within the limits of a U.S. port by vessel prior to its arrival. This notice, known as the Importer Security Filing or “ISF” must be filed no later than 24 hours before the cargo is laden on board a vessel at the foreign port. In everyday language, this means that US Customs must receive this information at least 24 hours before the cargo is loaded onto the ship.

There are 10 pieces of information, aka “data elements” that must be identified to US Customs for shipments that will be entered in to the U.S. or a foreign trade zone (FTZ), which is a location within the U.S. that, for customs purposes, is treated as if it were foreign territory in that goods may arrive there from a foreign port but not be considered to have “entered” yet. These 10 identifying data elements (supplied by the importer) along with 2 additional data elements (provided by the carrier) are:

1. Seller
2. Buyer
3. Importer of record number/FTZ application i.d. number
4. Consignee number(s)
5. Manufacturer (or supplier)
6. “Ship to” party
7. Country of origin
8. Commodity HTSUS number (tariff no.)
9. Container stuffing location (i.e., where container was loaded)
10. Consolidator (stuffer) (i.e., entity that packed the container)
11. Vessel stow plan
12. Container status messages relating to certain containers destined for the U.S.

Together these data elements are commonly known as "10+2."

US Customs claims in its published FAQs (see link on the right side) that updates to the ISF for known changes must be made prior to the goods entry into the first U.S. port and that amendments to the ISF will also be accepted at any time after their arrival. Be careful though, Customs likewise said in its FAQs that it will issue liquidated damages of $5,000 for each ISF transmission that is not timely, complete or accurate.

To help with better understanding the ISF requirements, US Customs is hosting a number of outreach events, including one tomorrow in New York City. For a list of their outreach schedule, click here.

More information on ISF and 10+2 can be found at 73 FR 71730, dated 11/25/08 and US Customs ISF Correcting Amendments (go to page 4 of this pdf file).

Additional instruction on this and other compliance measures workshops or webinars can be found through private companies such as TRG Direct. Thanks TRG Direct for your support!

Questions or comments? Feel free to email me at clark.deanna@gmail.com