Sign up for TRG Direct's Importer Security Filing Webinar
Next Available Dates:
July 29th 11 AM CT https://www2.gotomeeting.com/register/959358442
August 12th 11AM CT https://www2.gotomeeting.com/register/847719883
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If you are unable to make these times, please call us (847-756-7553) to scheduled a personalized demonstration or view our online demo.
Tuesday, July 28, 2009
Thursday, July 23, 2009
Importer Security Filing Compliance
Are you still contemplating how to establish and enforce advanced data reporting requirements under Importer Security Filing? Like preparing for a 400 Meter Relay, good communication and training is imperative; especially with something like this that carries stiff monetary penalties or could result in a "Do Not Load" message next January and requires significant change to the current methods in place for centries. Is your supply chain ready to hand off your ISF Baton?
Importer Security Filing Preparation
To reinforce the necessity for the ten (10) ISF data (excluding the bill of lading, number called the "phantom eleventh") elements, we strongly suggest that you consider amending your purchase order or other contractual agreements used in the transaction to require the vendor of supplier's compliance with ISF requirements. Some importers are also adding conditions to financial instruments like letter of credit. Placing such language in your contractual documents could prove to be a mitigation factor if CBP issues you a penalty for untimely or inaccurate data after January 2010.
We also suggest that you contact and closely coordinate activities with your ocean carriers, NVOCC's and freight forwarders participating in your import program. Meetings should be initiated between your supplier base and the carrier(s) at origin for purposes of ironing out new protocols and procedures for issuing the bill of lading number in advance. Since most major ocean carriers (Maersk, APL/NOL, Evergreen, Hanjim, NYK, K-Line, OOCL and others) are well informed on ISF; therefore if leveraged properly, their overseas offices can assist you with educating your vendor and supplier base. We recommend that you contact your US based carrier representative and request their overseas ofices engage problematic vendors or otherwise help you communicate this new requirement.
If your ISF Baton is dropped between transers, immediate disqualification may occur. Some imprters are instituting vendor penalties through their vendor compliance programs to incentivize compliance and to help offset the potential cost of CBP penalties levied against the importer.
Suggested Notifications for Your Suppliers & Vendors
It seems that the two most troubling situations for importer right now are the inability to get the bill of lading number in advance and/or lack of cooperation by suppliers and vendors. To that end, TRG Direct has developed recommended notifications for TRG Direct filers to send to suppliers and vendors. If you are currently direct filing with TRG Direct you can access these letters within your account under Resources. Suggested reading or attachments to your correspondence might include an Adobe copy of CBP Interim Final Rule (Federal Register Notice), copies of your new company policies or procedures, copies of other publications concerning ISF, and/or letters underscoring the importance and the support for the initiative from Senior Management.
Our ISF direct filing customers are free to use our suggested language or some variation thereor adapted for their company or particualr situatio in an effort to get compliance with their ISF program; of course the tone can also be adjusted according to personal preferences and corporate culture.
Sign Up Today!
Are you still contemplating how to establish and enforce advanced data reporting requirements under Importer Security Filing? Like preparing for a 400 Meter Relay, good communication and training is imperative; especially with something like this that carries stiff monetary penalties or could result in a "Do Not Load" message next January and requires significant change to the current methods in place for centries. Is your supply chain ready to hand off your ISF Baton?
Importer Security Filing Preparation
To reinforce the necessity for the ten (10) ISF data (excluding the bill of lading, number called the "phantom eleventh") elements, we strongly suggest that you consider amending your purchase order or other contractual agreements used in the transaction to require the vendor of supplier's compliance with ISF requirements. Some importers are also adding conditions to financial instruments like letter of credit. Placing such language in your contractual documents could prove to be a mitigation factor if CBP issues you a penalty for untimely or inaccurate data after January 2010.
We also suggest that you contact and closely coordinate activities with your ocean carriers, NVOCC's and freight forwarders participating in your import program. Meetings should be initiated between your supplier base and the carrier(s) at origin for purposes of ironing out new protocols and procedures for issuing the bill of lading number in advance. Since most major ocean carriers (Maersk, APL/NOL, Evergreen, Hanjim, NYK, K-Line, OOCL and others) are well informed on ISF; therefore if leveraged properly, their overseas offices can assist you with educating your vendor and supplier base. We recommend that you contact your US based carrier representative and request their overseas ofices engage problematic vendors or otherwise help you communicate this new requirement.
If your ISF Baton is dropped between transers, immediate disqualification may occur. Some imprters are instituting vendor penalties through their vendor compliance programs to incentivize compliance and to help offset the potential cost of CBP penalties levied against the importer.
Suggested Notifications for Your Suppliers & Vendors
It seems that the two most troubling situations for importer right now are the inability to get the bill of lading number in advance and/or lack of cooperation by suppliers and vendors. To that end, TRG Direct has developed recommended notifications for TRG Direct filers to send to suppliers and vendors. If you are currently direct filing with TRG Direct you can access these letters within your account under Resources. Suggested reading or attachments to your correspondence might include an Adobe copy of CBP Interim Final Rule (Federal Register Notice), copies of your new company policies or procedures, copies of other publications concerning ISF, and/or letters underscoring the importance and the support for the initiative from Senior Management.
Our ISF direct filing customers are free to use our suggested language or some variation thereor adapted for their company or particualr situatio in an effort to get compliance with their ISF program; of course the tone can also be adjusted according to personal preferences and corporate culture.
Sign Up Today!
Tuesday, July 21, 2009
We are nearing the 11th hour of Importer Security Filing. The mitigation guidelines were published in Cusoms BUlletin & Decisions on July 17th. At this time reality is setting in for many importers who have not prepared for this very serious regulation with stiff monetary penalties.
6 Months Down 6 More To Go
Rich DiNucci, Director, Secure Freight Initiative, recentrly presented statistics on the industry's compliance over the first six months of the ISF implementation phase. Customs and Border Protection has received 1.4 million ISFs from 57,000 importers. Of these fiings 46% have been timely. Is your company on of the 57,000? If so, keep it up, CBP will recognize your effort and you will be rewarded. If not, call TRG Direct today and we can get you set up with an ISF direct filing program within days. Face the facts, your progress during this probationary period will be a factor next January when fines/penalties come into play.
ISF Liquidated Damages
Four factors that may cause a loss of integrity in the ISF may result in liquedated damages. These include; failure to submit, late submission, failure to update or failure to withdraw. Penaltry amounts will be assessed as $5,000 per ISF transmission up to $10,000. The first and second vioations made by the company may be forgiven for less than the $5,000 penalty.
6 Mitigation Factos
There will be six mitigation factors used to determine the strength of the liquidated damages and whether or not the penalties are dismissed.
1. Progress of the importer's ISF program,
2. Percentage of ISFs containing violations,
3. Tier 2 & 3 C-TPAT members will receive consideration up to 50%,
4. Action taken by the importer after a violation has occurred,
5. Circumstances beyond the importer's control,
6. Inaccurate information received by another party within the supply chain.
It's Not Too Late. Your ISF Solution is Here.
Become a direct filing partner with TRG Direct to take control of your ISF. We can get you up and filing within days and help guide you through this new regulation. Let us help you develop a successful direct filing program and prove to CBP you are committed to compliance. Not only is TRG Direct the most user friendly system available, you can filed your ISF for onloy $3 - $5.
6 Months Down 6 More To Go
Rich DiNucci, Director, Secure Freight Initiative, recentrly presented statistics on the industry's compliance over the first six months of the ISF implementation phase. Customs and Border Protection has received 1.4 million ISFs from 57,000 importers. Of these fiings 46% have been timely. Is your company on of the 57,000? If so, keep it up, CBP will recognize your effort and you will be rewarded. If not, call TRG Direct today and we can get you set up with an ISF direct filing program within days. Face the facts, your progress during this probationary period will be a factor next January when fines/penalties come into play.
ISF Liquidated Damages
Four factors that may cause a loss of integrity in the ISF may result in liquedated damages. These include; failure to submit, late submission, failure to update or failure to withdraw. Penaltry amounts will be assessed as $5,000 per ISF transmission up to $10,000. The first and second vioations made by the company may be forgiven for less than the $5,000 penalty.
6 Mitigation Factos
There will be six mitigation factors used to determine the strength of the liquidated damages and whether or not the penalties are dismissed.
1. Progress of the importer's ISF program,
2. Percentage of ISFs containing violations,
3. Tier 2 & 3 C-TPAT members will receive consideration up to 50%,
4. Action taken by the importer after a violation has occurred,
5. Circumstances beyond the importer's control,
6. Inaccurate information received by another party within the supply chain.
It's Not Too Late. Your ISF Solution is Here.
Become a direct filing partner with TRG Direct to take control of your ISF. We can get you up and filing within days and help guide you through this new regulation. Let us help you develop a successful direct filing program and prove to CBP you are committed to compliance. Not only is TRG Direct the most user friendly system available, you can filed your ISF for onloy $3 - $5.
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