ô10+2ö outreach lauded as model for CBP programs
The effort to educate the import industry about the new ’10+2′ cargo security rule for advance shipment information has been so good that U.S. Customs and Border Protection should apply the same techniques to other programs, two members of an industry advisory panel recommended Wednesday.
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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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.
Banks said CBP should carry over those practices to the import safety arena as the government works to develop a new regulatory regime for protecting consumers from products made in foreign countries. CBP has set the model for using a risk-based, automated approach to monitoring import safety, and should use some of the lessons from the ’10+2′ implementation to get the cooperation of other agencies that have less experience dealing with cross-border trade, he said.
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