The ’10+2′ rule requires importers to electronically transmit 10 data sets identifying the origin, destination and contents of a shipment 24 hours before the vessel is loaded overseas, plus two data streams from ocean carriers. The rule has forced companies to make several fundamental changes to normal business practices as well as absorb extra costs for collecting and filing the information. But figuring out how to comply has caused confusion and angst within the trade community.
Customs has ‘brought a laser-like focus’ to carefully implementing the complex Importer Security Filing (ISF) rule with minimal impact on the trade, said Sam Banks, executive vice president for Sandler Travis Trade Advisory Services, during a Commercial Operations Advisory Committee (COAC) meeting in Washington. The border agency has ‘really created what I think is almost a best practice’ in terms of the industry engagement, metrics and detailed implementation strategy that should be replicated for other thorny issues, he said.
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American Shipper, BPE and ICPA have partnered on a study |
CBP consulted extensively with industry experts while drafting the rule, and after the rule was published in January launched an extensive outreach campaign featuring more than two-dozen public briefings at individual ports around the country to explain the requirements. Customs officials have also spoken at trade association conferences, and participated in conference calls and webinars hosted by private sector groups. The agency is also developing brochures and posters to get the word out about the pending enforcement deadline next January.
To further minimize the burden on businesses, CBP delayed enforcement for one year to allow companies time to develop systems and processes for organizing and filing the supplier data. Next week the agency will begin distributing periodic progress reports measuring at a broad level how well companies are doing with data accuracy and on-time filing.
COAC member Karen Lobdell also endorsed the concept of expanding the ISF communications strategy ‘to other areas and other programs where there hasn’t been outreach in the past’ or for getting the message out about future regulations.
Lobdell is director of trade security and supply chain services for Chicago-based law firm Drinker Biddle & Reath. – Eric Kulisch
Brokerage Compliance Symposium
The day before F3. Every compliance issue you face - fraud exposure, carrier liability, FMCSA rules, cargo theft, insurance gaps - navigated by attorneys and operators defining best practices in a changing industry.
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The night before F3. FreightTech100 companies honored. FreightTech 25 and Shipper of Choice winners revealed live. Cocktail reception into dinner and live music - 300 industry leaders in one purpose-built room.
F3: Future of Freight Festival
Industry-defining keynotes, rapid-fire technology demos, and industry leaders networking in experiences across Chattanooga - plus the inaugural F3 Awards Dinner featuring the FreightTech and Shipper of Choice reveals.
The day before F3. Every compliance issue you face - fraud exposure, carrier liability, FMCSA rules, cargo theft, insurance gaps - navigated by attorneys and operators defining best practices in a changing industry.
The Signal at Chattanooga Choo Choo • Chattanooga, TN Register NowThe night before F3. FreightTech100 companies honored. FreightTech 25 and Shipper of Choice winners revealed live. Cocktail reception into dinner and live music - 300 industry leaders in one purpose-built room.
The Signal at Chattanooga Choo Choo • Chattanooga, TN Register NowIndustry-defining keynotes, rapid-fire technology demos, and industry leaders networking in experiences across Chattanooga - plus the inaugural F3 Awards Dinner featuring the FreightTech and Shipper of Choice reveals.
The Signal at Chattanooga Choo Choo • Chattanooga, TN Register Now