Complying with the Importer Security Filing

On January 26, 2010, U.S. importers of ocean freight will not be permitted to cause cargo to be loaded onto a vessel at a foreign port without completing a properly executed Importer Security Filing (ISF).

ISF is the new regulation from Customs & Border Protection to assist in keeping ocean containers safe upon entering U.S. ports. ISF is also known as “10+2” because it requires the U.S. importer to electronically submit ten key pieces of data relative to the container’s contents 24 hours prior to loading, and asks the steamship line to electronically submit an additional two data points no later than 48 hours after departure.

The electronic importer filing may be completed directly by the importer or an agent may be used. The ten data points required of the importer are as follows:

1. Manufacturer name & address
2. Seller name & address
3. Buyer name & address
4. Ship-to name & address
5. Container stuffing location
6. Consolidator name & address
7. Importer of record number (IRS)
8. Consignee number (IRS)
9. Country of origin code
10. Commodity: HTS-6

An eleventh data element is actually required of the importer, which is the master bill of lading number. Although not readily discussed in 10+2 circles, the absence of this “extra” critical data element will cause a delay in your ISF process.

The two data points required of the steamship line are the vessel stow plan and a container status data message. All ISF filings must be submitted electronically via the Automated Manifest System (AMS) or Automated Broker Interface (ABI). If there are changes to the required data points, the party who performs the filing must update it before the goods arrive in the United States. Should cargo inadvertently get loaded at the foreign port, it will likely be off-loaded at another port of call prior to reaching the United States. As you might imagine, this would prove to be a challenging logistics endeavor. ISF is certainly not foolproof.

Years in the making, the ISF regulation effectively pushes the responsibility, and the risk for that matter, across the ocean and back to the foreign port. Customs & Border Protection is committed to fully supporting the trade community in its efforts to comply with the new regulation. ISF is currently in an informed compliance stage that concludes on January 26, 2010. The Department of Homeland Security has pledged to analyze the data procured during the informed compliance phase of ISF to determine whether the data points in the new regulation should be eliminated, modified or remain unchanged.

If you have not yet begun preparation for ISF compliance, time is running short. It is recommended that you begin your compliance in advance of the January 26, 2010, effective date to insure a smooth transition.

Sam Polakoff is president of TBB Global Logistics Inc., a licensed U.S. Customs Broker that specializes in the supply chain needs of small and mid-sized clients.

This article originally appeared in the Logistics Today digital magazine. To read other articles from that issue, click here:

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