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10+2 Customs Regulations
Made EZ
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Discover the Sweeping
10+2 Customs Regulations imposed by
The US Customs and Border Protection
And the Devastating Damages that
Can result from Non-Compliance
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On November 25, 2008, the details of the U.S. Customs and Border
Protection Importer Security ISF “10+2” Customs Regulation was announced.
Like most legal documents released by the Government and law making bodies, the
regulations is full of legalese and is sometimes hard to interpret. Because of this we
have attempted to simplify the requirements of the new 10+2 Customs Regulation by
translating the regulation into English that can be easily understood. We believe that
the report below will make the 10+2 Customs Regulation much easier to understand and
implement.
If by chance you still have questions, feel free to call us for clarification on any
issue.
If you would rather view a hardcopy of this report, you can download the
report by filling out the form to the right, and it will be e-mailed to you
promptly. |
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January 26, 2009
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This new law went into effect on January 26th, or 2009, but enforcement of the 10+2
Customs Regulation was intended to be “flexible” or advisory in nature until
January 2010.
The U.S. Customs & Border Protection rule known as 10+2 Customs Regulation or
Importer Security Filing (ISF) regulation, was implemented with the goal of
enhancing the U.S. Department of Homeland Security's ability to assess and identify
shipments entering the U.S as part of new anti-terrorism initiatives meant to
enhance the security of our water ports.
The new 10+2 Customs regulation requires the collection and reporting of 10 items
of data from importers (or their agents). There are two mandatory basic
reporting timelines that must be followed:
- The 10 items of data must be submitted at least 24 hours prior to the
loading of a vessel.
- The shipping line must submit two further items within 48 hours of vessel
leaving port and sailing.
The new 10 + 2 Customs Regulation is a paper less system and requires
that all data filing are to be electronic filing
only. Period. No paper submissions are allowed.
The U.S. Customs & Border agency graciously allowed a one year “flexible”
enforcement period so that importers would have sufficient time to develop a
feasible (for the importer) compliance program (for the importer), yet we have
found that many importers have procrastinated when it comes to preparing for
these additional requirements that will be mandatory in January 0f 2010 and time is
drawing near.
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Non-Compliance of 10+2 Customs Regulation Can be
Financially Devastating To Your Company
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The penalties for non-compliance of the new 10+2 Customs Regulation though
substantial at $5,000 fine per violation may seem small in comparison to the cost
of a full vessel shipment. If the $5,000 fine per violation does not shake you, the
possibility of a “No Load Order” that can be issued as a result of non-compliance
should put the fear of God into you because it can have a devastating effect
financially for your company and your clients.
If Customs issues a No Load Order on your shipment, your shipment will not be
allowed to be loaded on its intended vessel. You are probably aware of
this fact, but let me re-iterate, the vessel does not wait for you to fix the “No
Load order” with customs. The ship has a schedule to keep, and leaves on time, with
your shipment or without your shipment.
So the “No Load Order”, can result in your shipment sitting at the dock for days,
if not weeks before the “No Load Order” is released to be shipped.
Though the fine should be a large enough deterrent, the more damaging result is
that, there is a very high probability, that every one of your future
shipments will be subjected to increased scrutiny for some unknown
period of time into the future.
Though there is no formal red tag process or black list process, the resulting
increased scrutiny can result in:
- Shipment delays costing tens or even hundreds of thousands of dollars in
lost revenue
- Lost Business because of delays
If you have not started on implementing a compliance methodology,
I suggest you get started now, so that you have plenty of time to implement the
necessary compliance requirements. If you need assistance, Alliance Shipping Group
USA will be more than happy to assist or head up your compliance efforts. Just give
us a call.
In the next paragraph, you will find a very succinct description of what is
expected of you to comply with the 10+2 Customs Regulation. Make sure you watch our
15 minute video for further clarification. Again, if you need any
further clarification, just call us and we will be glad to answer any of your
questions. Below that are commonly asked questions and the appropriate answers.
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10+2 Customs Regulation
Data And Filing Time Requirements
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To comply with 10 + 2 Customs regulations, you the importer must supply the
following information for container shipments. (This rule does not apply generally
to break bulk or bulk shipments):
Following are the 10 data items (of the 10+2)that must be provided 24 hours prior
to loading:
- Manufacturer (or “final” supplier) name and address
- Seller’s name and address
- Buyer’s name and address
- Ship to name and address
- Scheduled container stuffing location or locations
- Consolidator name and address, if any
- For the importer of record, FTZ applicant identification number (IRS, SSN,
or number by assigned by Customs if other number not
available)
- Consignee identification number (IRS, SSN, Customs Assigned, CBP encrypted
ID)
- Country of origin where goods were manufactured, produced or grown
- Harmonized tariff schedule code at minimum 6-digit level
NOTE: There is a one time exception allowed:
Although it simplifies the filing if all items are filed at the same time, if items
5 and 6 (stuffer and stuffing locations) are not available at the time of the
initial filing, these two items may filed as soon as they are available, but in no
event later than 24 hours prior to the vessels arrival.
The 2 data items of 10+2 that must be provided must be provided by the shipping
line 48 hours prior to the vessel sailing
- A Vessel stow plan
- Container status information detailing specific information relating to
each container.
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10 +2 CUSTOMS REGULATION IMPACT
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Although the importers are ultimately responsible for 10+2 Customs compliance,
importers are generally customers, so the importer will depend on all links in the
supply chain to assist the importer's compliance of 10 + 2.
Although the casual observer may see that the exporter has no responsibility for
10+2, the 10+2 Customs regulation is already changing the way many exporters
do business.
For example, If an exporter ships a range of products from various manufacturers,
the information an exporter must provide to their customer base is likely to be
increased, in order for the importer to meet their 10 + 2 compliance requirements.
Similarly, the shipping line, 3PL, customs broker or 4PL, as the case may be, must
fast track the information interchange. From the exporter to the customs broker it
will be much more difficult to accommodate “last minute” orders because the 10
+2 compliance must be met according to the required time lines, which will
require more coordination and planning between all the links in the supply
chain.
Alliance USA and the Alliance Shipping Group are ready to provide the information
necessary to determine the best practices to comply with 10+2.
Because Alliance USA has a world wide network, Alliance is prepared to implement a
10+2 Customs regulation solution tailored for each client's needs, including
interfacing with the client's exporters overseas, or whatever is required to get
the job done.
Alliance will review and analyze the following:
- The data elements readily available in current information flow
- Existing systems capability and expandability to assist compliance.
- Possible data input sources, considering input accuracy and
accessibility
- Coordination of information among exiting 3PLs, shipping lines, etc.
- Review of exporter information reliability vis-à-vis other exporters
- Selection of ultimate filer
- Product tracking technology and other specific importer variables
With this information in hand and depending upon the client's customs
compliance needs, Alliance will be prepared to provide full 10+2 compliance
service or interface with the client's customs broker or other customs compliance
resources to ensure full and accurate 10+2 compliance on or before January
2010.
To answer any questions that you may have, we have provided many of the frequently
asked questions below, but again, call us at the phone number located in the footer
of this document, if you need any help, clarification, or if you need to utilize
our consulting services to assist you with compliance.
Below is a power point Video on complying with 10 + 2 Customs Regulation, and below
the video is a Frequently Asked Questions Section.
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“10+2” Customs Program Frequently Asked Questions
Importer Security Filing “10+2” ProgramDownload "10+2 Frequently Asked Questions"
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Alliance Shipping Group USA Specializes in
10+2 Customs Regulations
Consulting
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| Testimonials |
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| “Alliance USA gave us the distribution support in the US that was
essential to our growth. Alliance was responsive to our every need. More
importantly Alliance gave us insight into the US market that helped our growth
outside of the supply chain function.” |
| - Thierry Dubernard Promethean |
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| “Burley Appliances determined that it needed to expand to the US
market. Upon investigation, whilst the expansion was deemed necessary, the
expenditure required to establish an independent US office were daunting.
Alliance Group's USA office provided all the support our sales and marketing team
needed at a fraction of the cost we projected had Burley established its own US
office.” |
| -John Barson Burley Appliances |
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