Large companies and frequent shippers are mostly aware of the Importer Security Filing that went into effect in January and will be enforced beginning Jan. 26, 2010. The brochure is targeted at small importers who may not be aware of the rule and often walk into customs houses in port cities to manually file paper customs entries.
The brochure explains the ISF, who is required to file the document, what data elements must be filed for normal and special shipments, and enforcement procedures.
CBP's industry sounding board had expected the brochure to be published by the end of June so that importers have time to change their business processes to meet the requirements. The agency says that it takes at least 60 to 90 days for a company to ramp up automation, filing procedures and data collection efforts to comply with the rule.
Discussions about the brochure began in March and took a long time to go through proper channels for approval, Karen Lobdell, director of trade security and supply chain services for Chicago-based law firm Drinker Biddle & Reath, pointed out at a meeting of the Commercial Operations Advisory Committee earlier this month.
ISF Program Manager Richard DiNucci denied that CBP dropped the ball, saying that its priority was to make sure the brochure was completely accurate. During June and July there were still many interagency discussions going on about implementation procedures for the rule and officials decided it was better to hold off rather than issue four or five updated brochures, he told the industry representatives.
DiNucci acknowledged that creating the brochure was 'not a perfect process,' but said that importers are ultimately responsible for being aware of the regulatory environment in which they operate. The ISF rule has been under development for three years and CBP has held an extensive number of informational seminars in port cities across the country, he noted. The message about ISF is reaching most small shippers too because the vast majority of ISF filings to date are from small-and-medium-size enterprises, he said.
To see the online version of the brochure click here. ' Eric Kulisch
