CBP mulls ways to encourage unified ISFs

CBP mulls ways to encourage unified ISFs    U.S. Customs and Border Protection may offer incentives in the future to encourage importers to take advantage of a streamlined document filing option under the '10+2' advance data regulation, officials reiterated at the agency's annual Trade Symposium last week.
   The Importer Security Filing rule in effect since late January requires importers or their agents to electronically submit 10 sets of information plus the bill of lading number 24 hours prior to vessel loading overseas to help border officers analyze shipments for security threats. Much of the required information is already included on the customs entry or entry summary filed at, or prior to, arrival in the United States.
   To reduce redundant forms, CBP offered filers the option of submitting a unified filing. This offers a way for importers to submit their customs entry early and tag on two extra data elements required by ISF so that they don't have to file a similar document twice. Some companies that have complete data early enough are opting to submit the entry in advance to meet the ISF requirement.

DiNucci

   Richard DiNucci, director of the Secure Freight Initiative office, said only 2 percent of ISFs are submitted as unified filings. Trade professionals attribute the slow adoption rate to the challenge of adjusting internal software programs that communicate with CBP, nervousness about opening oneself up to penalties for administrative mistakes, and the simple fact that companies are overwhelmed trying to prepare systems to comply with ISF and don't want to add another layer of complexity to the process at this time.
   CBP officials gave more details at last week's event about internal discussions on how to provide trade benefits, such as process efficiencies or expedited cargo release, for those that file the entry summary early.
   Among the options are lowering the amount of trade compliance measurement exams and providing earlier cargo release decisions, said John Jurgutis, the chief program manager for ISF, said. Under current practice, importers can file their entry 30 days ahead, but only receive cargo release five days prior to vessel arrival. CBP is debating whether to extend that release window to the point of vessel departure from a foreign port, he said.
   CBP would have to resolve its own programming issues associated with such a policy decision, 'but if that option is taken there should be a benefit due to the trade for filing that data early,' DiNucci said.
   The unified filing is a good first step towards a true harmonized filing, but will take a lot of work before it is widely adopted by the industry, said Marianne Rowden, president of the American Association of Exporters and Importers, in a separate session.
   'I think it will take five years to get to that point,' she said.

Peterson

      Several attendees acknowledged that getting cargo release at vessel departure is a nice benefit because it would allow shippers to make distribution adjustments if they know a box with their goods is going to be held for inspection or other reasons. And shippers who use customs brokers or freight forwarders to prepare their customs documents could save money because they would only need the service once instead of twice.
   'It has a huge upside to the trade as long as it doesn't create delays or cost,' said Beth Peterson, president of international trade consulting and training firm BPE. ' Eric Kulisch