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.
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American Shipper, BPE and ICPA have partnered on a study |
Tier 3 members of the voluntary supply chain security program — those who have taken the most precautions to control their shipments — will begin to receive the progress reports within 30 days, followed by other companies in the program. There are more than 8,700 certified C-TPAT companies, including more than 250 Tier 3 importers.
Sharing the reports with C-TPAT members is a response to the trade community’s request to receive more trade facilitation benefits in exchange for making security investments, Winkowski said.
Richard DiNucci, program manager for ISF, said CBP would eventually send progress reports directly to a number of large importers as well to make their lives easier.
Under the so-called ’10+2′ rule, importers are supposed to collect 10 sets of data identifying the product, manufacturer, buyers and company that packed the container, and file the information 24 hours prior to vessel loading. Vessel operators are to transmit container status messages they normally share with customers and the container stow plans. CBP has delayed enforcement during the first year to help industry adjust to the rule, which requires many changes in business processes to organize the data and file it through approved systems.
The progress reports will measure how many ISFs a company filed per month, the on-time rate, whether CBP accepted or rejected the filing, and the overall accuracy for each of the data elements.
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| Winkowski |
‘Aggregate data won’t be sufficient to drive down to corrective action,’ especially for high-volume filers, she said. And many service providers are at various stages of readiness to map the aggregate data to their individual transaction records in a unified report for their customers, she warned.
CBP is receiving about 12,000 ISF forms per day, up 10-fold since the start of the program, DiNucci said. It has received about 720,000 filings as of May 4, including 21,000 filings for special cases such as freight remaining on board a vessel at U.S. port, in which only five pieces of data are required.
Ocean carriers have transmitted 25 million container status messages and about 1,600 stow plans so far.
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| DiNucci |
DiNucci said Customs’ systems have been able to process the high volume of data without any deterioration in performance.
He repeated that the rejection rate for inaccurate or incomplete ISFs has fallen to between 5 percent and 6 percent per day since the early days. Most of the errors that cause CBP to reject the filing are due to duplicate transmissions from filers who do not give the system enough time for a response before trying to resend. In other cases a filer may submit a form in test mode, receive an ISF transaction number and then resend the filing using the identification number. In a few cases, CBP has processed transactions twice. DiNucci said these are simple mistakes that can be easily corrected.
A small number of rejections involve invalid harmonized tariff numbers or city codes in address fields, which are considered simple data entry mistakes.
Another 4 percent to 5 percent of ’10+2′ filings are accepted with warnings, meaning that 90 percent of the filings overall are coming in clean.
‘The thing we’re not seeing is rejections because the data elements are not there,’ which means filers are able to pull together the information they need in a timely fashion, DiNucci said.
Only 3 percent to 5 percent of filers are taking advantage of the unified filing option, which gives importers the ability to piggyback their customs entry data onto the ISF filing, he said.
And less than 1 percent of filings take advantage of the flexible arrangements that allow shippers extended time windows to update certain of the data elements that are difficult to obtain, such as container stuffing location and consolidator. Those data elements are usually being submitted correctly the first time, he added. – Eric Kulisch
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