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Prepare Yourself for Advance Data Requirements
Customs and Border Protection Requiring Advance DataAction Required by All U.S. Importers Using Sea Freight Transportation Services to U.S. Ports.
Congress, acting through U.S. Customs and Border Protection (CBP), has mandated that importers using containerized sea freight (full and less than full) must transmit 10 data elements for each shipment, at least 24 hours prior to loading the shipment onboard a vessel. This is a sweeping change in advance data collection and is being required by Congress to increase security by increasing visibility. Customs currently targets suspicious consignments through the entry and manifesting data. This new requirement, called Importer Security Filing (ISF), will be exclusively the responsibility of the importer. This newly imposed regulation places a significant burden on the importing community at a time that, in most of our memories, has had more challenges than any other.
The data elements importers are required to file with Customs are:
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Seller
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Buyer
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Importer of record number
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Consignee number
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Manufacturer or supplier
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Ship-to-party
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Country of origin
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Commodity HTSUS (6-digit level)
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Container stuffing location
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Consolidator
The challenge is that most importers do not currently have access to these data elements 24 hours prior to loading a shipment on a vessel. Over the next 11 months, importers and their suppliers and service providers will be charged with making the necessary process changes to their supply chain and internal procedures to allow for the collection of this data.
Reilly International has programmed our computer system to be able to file this data. However, the collection of the data as yet remains a challenge. Our intention is to assist our clients in compliance, and since each supply chain is slightly different, we will work individually with our clients to achieve it. The first day importers were able to send this data to Customs was January 26, 2009, but most have not yet done so. This change in the supply chain will take time. Accordingly, Customs is treating the first year as a learning experience, giving the trade time to get it right and for Customs to digest the data being presented. Although compliance is not mandatory until January 25, 2010, importers are required to take active steps towards compliance.
Reilly International is facilitating our clients’ compliance with this new regulatory environment with a phased approach. We have attended the outreach session held by CBP and have begun sending ISF data. As is typical with new government regulations, the first 30 days of implementation has brought much more clarity in terms of the requirements. Although we realize our clients may be eager to comply with this new regulatory environment, we intend to balance our compliance efforts with a measure of careful, step-by-step implementation. We prefer to make this as easy as possible for you, as we are acutely aware of the challenging business environment we are all facing.
On March 24 and April 7, Reilly International will host introductory webinars to further update you on ISF. In the meantime, please do not hesitate to contact your client representative if you have any questions or immediate concerns.
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Congress, acting through U.S. Customs and Border Protection (CBP), has mandated that importers using containerized sea freight (full and less than full) must transmit 10 data elements for each shipment, at least
24 hours prior to loading the shipment onboard a vessel.
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