□ Why am I getting a “Duplicate” file message?
Someone has already used this bill of lading number to transmit an ISF --- maybe not your shipment. That is why you are getting the “duplicate” file message --- CBP will accept the ISF for the first importer that uses the bill number and will reject any subsequent filings with the same bill number. So, in order to be compliant with the requirements of ISF and if the carrier cannot discover the error on their part, you could request that they issue you a new bill number so that you can correct your ISF filing and retransmit with another bill number. When you receive a reject for your ISF --- it is as if you have not filed the information with CBP.
Unfortunately CBP has not provided the filers with any advice on what to do to try and solve this problem (and for right now, until Jan. 26 --- there will be no penalty for failing to file an ISF). The only advice we can give is for you to work with the Bill issuer to resolve whatever problem is resulting in your filing being rejected by CBP, with the last resort, your insisting that you need a new bill number so that you can file your ISF.
All of your attempts to resolve this duplicate file reject should be maintained in the system “notes” file to assist with any response to an enforcement action that CBP might take for ISF’s filed after January 26th.
□ Do rollover shipments need new ISFs?
If you have some cargo that made the shipment but others that are rolled over, you should update the ISF with the information about the cargo that made the shipment. If the ISF has already been transmitted with a bill of lading (BOL) that is being rolled over, you will need to take that BOL off of that ISF as well and request that a new BOL be issued for the rolled over cargo. You will then create a new ISF for the rolled over cargo with the new bill of lading.
If an entire shipment is rolled over, you will need to update the ISF if any of the information has changed, including the new bill of lading. If the information is exactly the same, then you don’t need to do anything.
It may seem difficult to receive a new BOL for a rolled over shipment, but if you have already transmitted an ISF with that BOL, then you will receive a rejected ISF with a Duplicate ISF Transaction error message because Customs will not accept more than one ISF with the same BOL. This can seem problematic, but this is a situation that every vendor will eventually have to deal with and accommodate.
□ What is an AMS Bill of Lading?
ISF has brought the term “AMS bill of lading” into the importer’s vocabulary, causing even more confusion as to what BOL Customs wants when the importer submits an ISF. The AMS bill of lading is whatever bill of lading is entered into AMS. This is the BOL that you want on your ISF because it is what Customs matches the ISF BOL with the BOL entered into AMS. Even if you believe you import under a house bill or straight bill of lading, it is helpful for you to ask your carrier or freight forwarder for the AMS bill of lading so that you know that your ISF will be matched properly.
□ Why haven’t I received a response from Customs after filing an ISF?
If you have filed an ISF and have not received a timely response from Customs, don’t worry. This occurs when the CBP’s system gets overloaded and overwhelmed. If this happens, don’t fret; your ISFs have been transmitted and Customs will be aware of the hold up. All you can do is sit and wait for the system to clear up.
□ Can I file my ISF early?
TRG Direct recommends filing as soon as you get all of the accurate data elements. However, if you file your Importer Security Filing before the bill of lading is entered into AMS, you will get a No Bill on File message since there is no bill of lading to match it to in AMS. When this happens, the system will cycle the entry through until the bill matches. Filing an ISF as soon as you have the information is a good way to ensure you file timely. The No Bill on File message will not result in a negative result on your progress report. The sooner CBP receives the information the better because this gives them more time to look through the information and screen it.
□ What is an invalid transaction error?
This occurs if somebody attempts to submit an ISF that has already been submitted by a different entity or the information was the same as a deleted ISF. This happens often if you go back and attempt to resubmit an old ISF or if you change your filer code and attempt to resubmit an ISF.
□ Definitions of the Entities (Data Elements).
Importer – The entity that is liable for duties and taxes and that is liable for federal regulations when importing into the United States.
Consignee – The entity on whose account the items are shipped. This is usually the same as the Importer.
Ship To – The name and address that will receive the goods as soon as they clear Customs. This is often the Importer.
Manufacturer – The name and address of the company producing the goods.
Seller – The name and address of the person selling the goods. If they are household goods, this is generally the name and address of the owner. This is often the same as the Manufacturer.
Buyer – The name and address of the entity purchasing the goods. If they are household goods, this is generally the name and address of the owner. This is often the Importer and/or Ship To.
Container Stuffing Location – The name and location of the place where the goods will be stuffed into the container.
Consolidator – The person who arranges for the stuffing of the goods.
HTS – Customs accepts both the 6 and 10 digit Harmonized Tariff Schedule number. It is unnecessary to indicate how many of each item.
Country of Origin – Customs requires the country of where each HTS originated.
Bill of Lading – This is known the hidden 11th element. The lowest bill of lading is required for all ISFs.
□ What are the different ISF transaction types?
A “Compliant Transaction” is used when you are sending 10 accurate ISF data elements. This means you are telling Customs that everything within the ISF is correct (to the best of your knowledge).
“Flexible Range” is used when you are not sure what items will be included in the shipment. If this is the case, you would enter every possible HTS code and file using “Flexible Range.” However, once you receive accurate information, you need to update the ISF before the ship arrives in port. Once you update and retransmit, Customs will consider the ISF a “Compliant Transaction.”
“Flexible Timing” is used when you are unaware of the Consolidator or Stuffing Location. Since these items were not necessary previously, Customs allows you to file your Importer Security Filing under this transaction type without those entities. However, like “Flexible Range,” the ISF must be updated and retransmitted before the ship enters port.
When you file using the Flexible options, you will receive an Accepted with Warnings message and the error message “Complete Transaction Required.” This is to remind you that you need to update the ISF and retransmit it using the Compliant Transaction type 24 hours prior to arrival. The Accepted with Warnings message will appear yellow in the ISF dashboard so it’s easy for you to see that it needs to be updated.
□ How can I possibly get the Bill of Lading Number on time?
CBP has tried hard to let the shipping community know that the bill of lading has to be issued earlier. Some vendors are using the booking number as the bill of lading to rectify this situation. Most importers require the bill of lading at least 48 hours prior to lading. If you don’t receive the BOL before the ship is laden, you will be late. If you are a TRG Direct ISF customer, we have letters that you can send to vendors letting them know that you need the essential data elements early. If they don’t comply, we can go to CBP and have them deal with noncompliant vendors.
□ I have done everything I could to transmit a compliant ISF, but was still unable to do so. How do I let Customs know I tried?
The notes field is a way for customers to make any notes of any peculiarities on a particular ISF. If anything worth noting happens while filing an ISF, it is important that you make a note of it in this field. The notes will not be submitted to Customs, but it is a safety net for you in case you incur any ISF penalties. That way, if CBP attempts to penalize you on an ISF, you can go into your notes field, remind yourself on the circumstances of that particular ISF, and then use it to show Customs that you performed due diligence to file timely and accurately. This can help greatly when trying to mitigate penalties. The notes field can be edited and updated as often as you like.
