AAEI says 10+2 Costs will Mount

The American Association of Exporters and Importers (AAEI) in comments filed last week urged caution over the costs of U.S. Customs’ Importer Security Filing (10+2) interim final rule. 10+2 requires cargo information to be transmitted to CBP agents at least 24 hours before goods are shipped to the United States.

AAEI expressed concern to U.S. Customs and Border Protection (CBP) that the costs of 10+2 compliance are still unknown. In the first months of implementation, the only cost CBP is capturing is the transaction fee for filing. However, AAEI notes that the true costs are much higher, especially for small and medium-sized enterprises. Plus, hidden costs of 10+2 compliance will add up quickly due to delays and slowdowns in the supply chain.

AAEI is also concerned about the lack of tangible benefits for voluntary participation in the costly C-TPAT program, and recommends that CBP allow C-TPAT members to satisfy 10+2 requirements by providing routine data at the aggregate level for common shipments.

For more information, please visit http://www.aaei.org

CBP Amends "Imported Directly" Requirement under Bahrain FTA

U.S. Customs and Border Protection (CBP) has amended its regulations on an interim basis to change certain provisions relating to the requirement under the U.S.-Bahrain Free Trade Agreement that a good must be imported directly from one country to the other to qualify for preferential tariff treatment. This rule removes the condition that a good passing through the territory of an intermediate country while en route from one FTA party to the other must remain under the control of the customs authority of the intermediate country, a condition that is not contained in either the FTA or the U.S. law implementing it.

As a result of this change, the only requirement for a shipment passing through an intermediate country to be considered to be imported directly under the U.S.-Bahrain FTA is that it not undergo production, manufacturing or any other operation outside the territories of the U.S. or Bahrain other than unloading, reloading or any other operation necessary to preserve the good in good condition or transport it to the U.S. or Bahrain. Operations that may be performed in an intermediate country include inspection, removal of dust that accumulates during shipment, ventilation, spreading out or drying, chilling, replacing salt, sulfur dioxide, or aqueous solutions, replacing damaged packing materials and containers, and removal of units of the good that are spoiled or damaged and present a danger to the remaining units of the good, or to transport the good to the U.S. or Bahrain.

This rule is effective as of May 22.

To read this article, please visit WorldTrade\Interactive.

Speeding US Import Clearances

Successful steps have been taken to allow importers and US Customs and Border Protection (CBP) to more completely file and process most common entry summaries. CBP explains that entry summaries represent 96% of all entries filed each year. Now, through the Automated Commercial Environment (ACE) program Secure Data Portal importer account holders can opt to receive and respond to CBP forms electronically.

Commenting on the initial implementation of the expanded capabilities, Louis Samenfink, ACE program executive director, said: "This is an exciting year for those who work on and with ACE as we have successfully begun the deployment of new automated entry summary processing features, and will deploy the replacement of current rail and sea automated manifest systems by mid-summer. More than 20,000 CBP and participating government agency end users will be affected by these innovative electronic processes."

To read the full article, please visit Outsourced Logistics.

ISF Filers Can Register for Report Cards

Importers or their logistics providers need to register to receive performance reports on how well they are complying with the “10+2” rule, U.S. Customs and Border Protection said in a message to the import community on Monday.

CBP is preparing to send out the report cards to companies that have submitted Importer Security Filings under the advance trade data rule that went into effect in late January. The reports are expected to indicate how many filings a company has submitted, whether they have been accepted or rejected, the on-time ratio, and grade for accuracy each of the 10 data elements in the document.

Filers must send an e-mail to progress_report@cbp.dhs.gov and include the following information:

• Filer’s corporate name.
• Filer code used for ISF.
• Point of contact and telephone number.
• Corporate e-mail address to which report will be sent.

CBP will call the point of contact to verify the information. Questions should be directed to Chuck Miller, (703) 553-1772.

For more information, visit CBP's site.

Lacey Act Declaration Enforcement Delayed, Filing Procedures Clarified

The Department of Agriculture has issued a notice updating the trade community on the implementation of the import declaration requirement under the Lacey Act amendments. Specifically, the USDA is delaying the initial stage of enforcement of this requirement and clarifying the procedures for filing the declaration.

Enforcement. Under the Lacey Act amendments, imports of certain plants and plant products must be accompanied by import declaration containing the scientific name of the plant, the value of the importation, the quantity of the plant and the name of the country from which the plant was harvested. For paper and paperboard products containing recycled content the declaration must also include the average percent of recycled content regardless of species or country of harvest.

The USDA has now modified the schedule of phased-in enforcement of the declaration requirement that it had previously announced. As a result, while the electronic submission of the required data elements will be accepted starting April 1, enforcement will not actually begin until May 1. As of that date U.S. Customs and Border Protection will enforce the declaration requirement for imports under HTS headings 4401 (fuel wood), 4403 (wood in the rough), 4404 (hoopwood; poles, piles, stakes), 4406 (railway or tramway sleepers), 4407 (wood sawn or chipped lengthwise), 4408 (sheets for veneering), 4409 (wood continuously shaped), 4417 (tools, tool handles, broom handles), and 4418 (builders’ joinery and carpentry of wood).

USDA is encouraging importers to use this 30-day period for live testing of the electronic system. The government will use this time to complete its work on integrating the Lacey declaration requirement into CBP’s expedited border release programs.

It is not anticipated that enforcement of subsequent phases, as detailed below, will be delayed.

CBP has automated the process for collecting the required data elements and expects and urges most importers to use the electronic system to file the declaration. Specifically, data will be transmitted to the Automated Commercial System through the Automated Broker Interface in the cargo release module. Electronic filing of the declaration will not preclude remote location filing.

Importers will have the option to complete and present a paper declaration for each line, but if a paper form is used it must be mailed to USDA at the address on the form. If a paper form is submitted to CBP as part of the entry package it will be returned to the importer (or importer’s representative) for mailing to USDA.

For more information on deadlines and filing procedures, please visit the USDA at http://www.usda.gov

More information will also be available from Customs and Border Protection at http://www.cbp.gov

Why Comply?

The US Government is taking unprecedented steps to protect national security, and nowhere is the impact of that effort felt more than at the country's entry points. For global shippers, this heightened security consciousness presents myriad challenges when it comes to clearing goods through US Customs and Border Protection (CBP), which requires more and allows for less than ever before.

Failing to understand and comply with the latest CBP requirements can cost shippers and importers serious time and money. A spot inspection can delay the movement of material for several hours; a hold can delay it for several days.

The good news is that CBP offers new tools and programs to help shippers and importers meet its new, stringent requirements. If shippers had to choose one action that would help expedite the movement of goods through Customs, it's to become certified under the Customs-Trade Partnership Against Terrorism (C-TPAT) program.

CBP launched the C-TPAT initiative in an effort to help it work more closely with businesses to improve border security. To qualify for C-TPAT certification, shippers and importers must meet a variety of requirements in several categories, ranging from business practices and record-keeping to facility security and developing working relationships with supply chain partners on security issues.

To understand more about the latest CBP programs and requirements, view the full article on page 36 in the February 2009 edition of the Journal of Commerce.

Global Logistics Regulation: Time's Up!

The clock has been ticking for several years, and now shippers must acknowledge that the time for embracing regulatory standards has arrived. Who’s ready for the onslaught of regulatory change?

While “change” may be the operative word when it comes to regulatory compliance this year, shippers realize that “or else” is the unstated maxim. Industry analysts have been suggesting for years that by conforming early to government mandates, shippers may actually be gaining something beyond improved security—a sharpened competitive edge. Well, your friends at Department of Homeland Security (DHS), Customs and Border Patrol (CBP), and The Transportation Security Administration (TSA) certainly think so, as do many supply chain specialists who maintain that security equals efficiency.

At this moment, the much-maligned 10+2 rule is being fine tuned during its “interim period” for ocean shippers, and air shippers are trying to cope with 50 percent screening of inbound and outbound cargo.

To find out where things stand on the regulatory front - and where things may be going if there's enough resistance, please visit Logistics Management at http://www.logisticsmgmt.com/article/CA6635274.html

Basham to Step Down

Press sources are reporting that U.S. Customs and Border Protection Commissioner Ralph Basham will step down February 28. Deputy Commissioner Jay Ahern will serve as acting commissioner until a replacement is nominated and confirmed by the Senate. A Journal of Commerce article cited a Department of Homeland Security spokeswoman as saying DHS Secretary Janet Napolitano has been speaking with potential candidates.

This article can be found at WorldTrade/Interactive at http://www.strtrade.com/wti/wti.asp?pub=0&story=30279&date=2%2F13%2F2009&company=

10+2 Filings Show Improvement

The rejection rate for inaccurate or incomplete Importer Security Filings has fallen to about 15 percent since the new advance electronic document became a requirement two weeks ago, program manager Richard DiNucci said.

The so-called "10+2" rule, a reference to the number of data types importers and ocean carriers must submit to CBP, went into effect on Jan. 26. The data elements focus on descriptions of the origin, contents and destination of the cargo. CBP is plugging the data into its targeting system for high-risk shipments. As of Friday, CBP has received about 30,000 filings and more than 2,000 unified filings from importers or their designated agents.

CBP Does Its Part To Stimulate Economy

Companies are shedding jobs at an unprecedented rate as the U.S. economy weakens, but U.S. Customs and Border Protection is offering hope to thousands of people as it looks to fill 11,000 law enforcement officer and support positions this year.

On Saturday, the agency launched a national recruiting campaign with open houses at 15 locations across the country. CBP said 22,400 applicants attended the one-day event to learn about CBP's mission, career options and how to apply for a job.
More than 6,000 people turned out in both Detroit and Laredo, Texas.

To view the full article, visit American Shipper at
http://www.americanshipper.com/NewWeb/News/shippers-newswire/logistics/122897--cbp-does-its-part-to-stimulate-economy.html