Under the regulation, importers must electronically transmit 10 pieces of data about their international shipments 24 hours prior to vessel loading in a foreign port. Carriers must submit two other data streams at a later point.
The drop in scores last month for timely filing of the new cargo security form coincided with Customs and Border Protection's implementation of a secondary method to measure the timeliness of an ISF filing against the vessel departure date instead of simply versus the first bill of lading filed by the carrier with the cargo manifest. The move was intended to help importers avoid inadvertent late penalties that may have resulted from the carrier submitting the bill of lading early and making it appear the ISF was late even though it was filed before the cargo loading deadline.
Using the later vessel departure time as a compliance marker should have helped improve on-time scores for filers, but many experienced an opposite effect.
One major retailer that has built up strong ISF filing procedures saw its timeliness results drop about 10 percent, according to the company's import manager.
'People are freaking out because their timeliness is way down for filings that showed on-time in the past. Our on-time rate is down from 74 percent to 60 percent,' said Kelby Woodard, executive vice president of TRG Direct, a software and service company that provides customs support to hundreds of customers.
'The vessel departure metric is new. We had a few technical issued with getting the data lined up correctly. Hopefully the January reports will reflect much better timeliness,' John Jurguits, chief program manager for ISF, said in a phone interview.
The report cards — CBP prefers the term progress reports — are intended to show filers how well they are doing providing accurate and timely information, but many trade practitioners say the documents are not detailed enough to help them correct specific filing problems.
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| DiNucci |
'Make the best attempt to get it to us timely and I bet it will be timely,' DiNucci said, adding last week that timeliness rates were above 70 percent.
The agency intends to begin full enforcement of the so-called '10+2' rule on Jan. 26 after a one-year phase-in period to help businesses reengineer their processes for obtaining necessary data from overseas suppliers, and automate data gathering and filing. ' Eric Kulisch
