Importer Security Filing 10 2

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Importer Security Filing - 102

• Well Make It Work For You

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Where Did ISF Come From?

• SAFE Port Act of 2006 enacted by U.S. Congress in
  October of 2006
• SAFE Port Act Mandated CBP To
• Collect additional data elements,
• Require data to be received before loading,
• Improve the targeting process.
• NPRM January 2, 2008
• Proposes 19 CFR 149, Amends Several Other Sections

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What is the ISF

• Data Elements Transmitted to CBP
• 10 Entry Level Data Elements (ISF 10)
• 2 Carrier Oriented Data Elements
• 5 Entry Elements for FROB, IE, TE, FTZ (ISF 5)
• Goal
• Ensuring Cargo Safety and Security, Prevent
  Smuggling
• To Provide ATS Enhanced Security Screening

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Who Is Required To File

• Carrier the 2
• Carrier is Defined by 19 CFR
• The 2 Data Elements
• Importer the ISF 10
• New Definition of Importer under 19 CFR 149
• the party causing goods to arrive within the
  limits of a port in the United States.
• The 10 Data Elements
• Importer / Filer of Data the ISF 5
• For FROB, IE, TE, and FTZ
• the party filing the FROB, IE, TE, or FTZ
  Documentation.

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The 10 Required Elements

• Technical Specifications - ISF 10
• Manufacturer (or supplier) name and address
• Seller name and address
• Buyer name and address
• Ship to name and address
• Container stuffing location
• Consolidator (stuffer) name and address
• Importer of record Number
• Consignee Number (IRS)
• Country of origin
• Commodity HTSUS number

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The 2 Required Elements

• Vessel Stow Plan
• vessel name and operator voyage number
  container operator equipment number, size and
  type stow position hazmat code and
  load/discharge ports
• Container Status Messages
• terminal container movements, change in container
  status , focused on container status messaging
  set equipment number event description, date,
  time and location and vessel.

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The 5 Required Elements

• Technical Specifications ISF 5
• Booking Party Name and Address
• Foreign Port of Unlading
• Place of Delivery
• Ship to Name and Address
• Harmonized Tariff Schedule at minimum 6-digit
  level
• Current thought is that the carrier will file
  these data elements in most situations

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How and When Will the ISF Be Filed?

• How
• In the Entry Message by a Customs Broker
• In the Manifest by a Carrier
• As a Separate Filing by a Security Filer, Broker,
  or Carrier
• When
• 24 Hours Prior to cargo being laden on a vessel
  destined for the United States

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Concerns for Importers

• Who Will File?
• Importer Bears the Liability for Filing
• Regardless of who transmits the data on behalf of
  the importer
• Caution is urged in selecting a transmitter of
  the data
• Confidentiality of Data is Paramount
• Independent ISF Filers
• Not proven in current filing
• Must source ABI or AMS data
• Must go through a testing protocol
• May not be cost effective out of the gate

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Concerns for Importers

• Information Flow
• Large changes in the data flow may be required
• Obtaining additional data elements seen as the
  most challenging item
• Additional parties may be included, such as
  overseas freight forwarders
• Automation changes may be required between
  supplier importer ISF Filer
• Planning now is a must

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Sources of Information
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Questions to Consider as an Importer

• Exposure
• Where will information come from?
• Who will provide information to my filer?
• Who will file the information for me?
• When will the information be needed?
• How will the information be given to my filer?

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Questions to Consider for an Importer

• Is my data secure?
• What if there are changes that need to be made to
  the ISF filing?
• What if a supplier ships cargo without our
  knowledge?
• Can my Customs Broker do my filing for me?
• Should I file ISF with the entry, or not?

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The Logical Filing Party

• The Licensed U.S. based Customs Broker
• Confidentiality of importers information is
  required by law
• Accountability to client
• Proficient in ever changing U.S. Customs laws and
  requirements
• Only party in the supply chain licensed by CBP
• Familiarity with importers product and
  requirement
• A part of the importers team
• No major Carriers are planning to file the ISF 10

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When Does This Take Effect?

• The regulatory changes must be published as a
  Final Rule before implementation.
• The Final Rule is expected to be published at the
  end of summer 2008.
• The regulations will take effect 90 days after
  the publication of the final rule.
• CBP has indicated that there will be a one year
  informed compliance period to address changes
  to the current supply chain.

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COMPANY NAME

• CONTACT INFORMATION
• Phone / Email