Richard DiNucci, Secure Trade Initiative Director, attended TRG Direct’s self filing user group webinar presenting timely information on Importer Security Filing (10+2 ISF). The presentation by Mr. DiNucci provided importers with information about the current status of ISF filing and what importers can expect when ISF compliance begins on January 26, 2010. Importer Security Filing requires both importers and carriers to submit additional information pertaining to cargo for import into the United States, to Customers and Border Protection (CBP) 24 hours prior to the goods being laded for the U.S.
Mr. DiNucci has been traveling throughout the U.S. and various overseas locations as part of CBP’s Importer Security Filing Trade Outreach Program. Mike Laden, President of TRG Direct, took part in many of these sessions as a guest speaker. Between Rich and Mike, as well as other ISF trade data collected by CBP over the past year, TRG Direct’s user group was presented with an optimistic overview of the self filer’s progress to date. www.trgdirect.com
Currently, 4 million ISFs have been filed by 80-90% of U.S. importers. Around 10-20% of importers have not started filing. Between 35,000-40,000 ISFs are filed daily with timeliness averaging at 60%.
Although filing numbers are high, challenges still exist. The Duplicate ISF Transaction rejected message recently went up 3%, meaning more than one ISF is filed with the same bill of lading. This may be due to new filers or because of the many updates in the CBP system. CBP updated their system to only accept data in a particular format.
Mr. DiNucci said that in order to see how CBP will treat enforcement, importers can refer to the mitigation guidelines. “CBP is not in it to generate revenue,” Mr. DiNucci said, “but to get the data.” Mr. DiNucci said that importers who are already filing can expect a light touch from CBP due to the “relaxed enforcement” approach CBP will take. CBP will be harder on those importers who haven’t been filing.
“This meeting with Rich could not have come at a better time for our self filers. Luckily for those filers still completing their sign up with TRG Direct, we were able to record the presentation and have posted it online for download,” stated Gregg Cummings, National Sales Manager. www.trgdirect.com/isf_usergroup.aspx
Mr. DiNucci touched on the latest progress reports issued in early January. Timeliness was a large issue for many importers, and this may be because CBP measured timeliness differently in these reports. This time, CBP measured timeliness based on departure date; they expected that timeliness rates would improve, but unfortunately, progress reports worsened for many importers. Mr. DiNucci believes most importers are filing on time, and he said CBP will not see timeliness generating enforcement concerns until their measurement is refined. “The key point,” Mr. DiNucci said, “is to refine your system and take a deep breath; CBP will not say importers are not compliant based on timeliness.”
According to Mr. DiNucci, CBP appreciates the fact that importers are preparing for enforcement. They understand that importers are doing all the work, and CBP appreciates it. Mr. DiNucci assures importers that CBP knows importers will have issues in the beginning, but as long as they strive to provide the data to Customs, they don’t have to worry about enforcement.
“We’ll come down when we need to come down hard on those who don’t want to comply,” Mr. DiNucci said. “We don’t expect perfection at first. Just keep filing, take a deep breath, and you’ll be fine.”
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