As you know, Importer Security Filing (10+2 ISF) is a government mandate requiring importers to file additional data elements for all shipments entering the U.S. via ocean cargo.
Tips for your Importer Security Filing success!
As you continue to improve your ISF program to avoid the $5,000 penalties, please review these helpful tips. If you are using a broker/freight forwarder or you are filing direct, keep these in mind.
• Evaluate your ISF record: Have you requested your ISF progress report? Whoever is filing your ISF should provide you with a copy of this report that comes directly from U.S. Customs (CBP). If your ISF filer has not done so already, request this from him/her or contact me to see how you can request this directly from CBP. See an example ISF report here.
• Always File: You are better off filing late than not filing at all. Your policies and procedures should make sure that each ocean shipment has an ISF filed 24 hours prior to the departure of the vessel OR sooner. However, should an ISF be missed, your policies should ensure that an ISF is filed as soon as possible before the ship reaches the port of arrival.
• Keep Notes: Make sure that you and/or your filer maintain detailed records of everything done in order to file an accurate and timely ISF. Should mitigation need to take place for an ISF, CBP will want to see that you performed due diligence to file correctly and on-time.
• Ask Questions: The more you understand the process, the smoother the filing will go. In most cases, you are doing the majority of the ISF filing and your filer is simply hitting the transmit button. It is up to you to be aware of problems that may occur. Review our FAQs here.
• Evaluate resources: Should you find that your ISF compliance is below par and your costs to import are increasing due to ISF penalties, look into the other options available. I’d be happy to discuss in detail with you the pros of direct filing and see where you will be able to decrease your costs while increasing your compliance.
Showing posts with label isf direct filing. Show all posts
Showing posts with label isf direct filing. Show all posts
Monday, April 19, 2010
Tuesday, December 29, 2009
FAQs by Importer Security Filing Self Filers
□ 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.
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.
Monday, October 19, 2009
ISF Direct Filing Customer Service Blog with Jamie Dinan
Jamie Dinan has been running a fabulous blog for our direct filing customers. The blog is dedicated to ISF FAQs and updates. Jamie is a very talented writter and extremely knowledgeable on Importer Security Filing and self-filing.
Here is the link to the blog: http://isfsoftware.wordpress.com/
This is a great resource for customers as well as those importers who are looking into direct filing as a solution for ISF. TRG Direct is completely web-based and requires no start-up fee for filing your ISF. Check out Jamie's blog and let us know if you are interested in a demonstration.
Here is the link to the blog: http://isfsoftware.wordpress.com/
This is a great resource for customers as well as those importers who are looking into direct filing as a solution for ISF. TRG Direct is completely web-based and requires no start-up fee for filing your ISF. Check out Jamie's blog and let us know if you are interested in a demonstration.
Monday, October 5, 2009
Begin Filing Your ISF Today
We are getting so close to the Jan 26th deadline. As D-Day approaches importers are scrambling to find their compliance solutions. Many importers began filing by using their broker. They said, "I don't have time to deal with this, you deal with it". Now as they begin to review their report card and find that even though their broker is filing, they still are not compliant.
HELP! Frantically importers are looking to other options, some think it is too late to learn how to file in-house, but they are wrong. We have about 3 months to get you up and running and compliant. Let's start today. Atalanta, a direct filer of ISF and customs entries through TRG Direct is 99% compliant after filing ISF in-house after 3 months. It is doable. The most important thing is that CBP sees that you are taking the right steps toward compliance.
Call us today, we can help. 800-685-6082
HELP! Frantically importers are looking to other options, some think it is too late to learn how to file in-house, but they are wrong. We have about 3 months to get you up and running and compliant. Let's start today. Atalanta, a direct filer of ISF and customs entries through TRG Direct is 99% compliant after filing ISF in-house after 3 months. It is doable. The most important thing is that CBP sees that you are taking the right steps toward compliance.
Call us today, we can help. 800-685-6082
Tuesday, September 1, 2009
Easy Application Process for Direct Filing ISF
TRG Direct will make the transition into self-filing ISF as easy as possible. As a direct filing importer you will simply need to provide us with a Power of Attorney (POA) and payment information. The POA is needed because you will actually borrow our filer code. Since ISF is not considered "Custom's Business" this is exceptable. Next, you can pay via credit card or ACH and you are ready to file.
The sign up process can be done online and we can get you set up in our system in less than 1 day.
Our ISF customer service line is available to our clients at no extra charge along with our monthly user group meetings. ***Another new addition to our customer service is our ISF customer service blog, Jamie Dinan our TRG Direct sales administrator updates this blog with new trends following importer security filing. Access this blog here (whether or not you are a TRG Direct filing customer).
The sign up process can be done online and we can get you set up in our system in less than 1 day.
Our ISF customer service line is available to our clients at no extra charge along with our monthly user group meetings. ***Another new addition to our customer service is our ISF customer service blog, Jamie Dinan our TRG Direct sales administrator updates this blog with new trends following importer security filing. Access this blog here (whether or not you are a TRG Direct filing customer).
Tuesday, August 25, 2009
ISF Vendor & Supplier Compliance
Are you still contemplating how to establish and enforce the 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 that could result in a “Do Not Load” message next January and requires significant change to the current methods in place for centuries. 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 suggests that you consider amending your purchase order or other contractual agreements used in the transaction to require the vendor or supplier’s compliance with ISF requirements. Some importers are also adding conditions to financial instruments like letters of credit. Placing such language in your contractual documents could prove to be a mitigating 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 the ocean carriers, NVOCC’s and freight forwarders that participate in your import program. Meetings between your supplier base and the carrier(s) at origin should be implemented for purposes of ironing out new protocols and procedures for issuing the bill of lading number in advance. Most major ocean carriers (Maersk, APL/NOL, Evergreen, Hanjin, 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 offices engage problematic vendors or otherwise help you communicate this new requirement.
If your ISF baton is dropped between transfers, immediate disqualification may occur. Some importers 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 importers right now are the inability to get the bill of lading number in advance and/or lack of 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 polices or procedures, copies of other publications concerning ISF, and/or letters underscoring the importance and their support for the initiative from Senior Management.Our ISF direct filing customers are free to use our suggested language or some variation thereof for their company or particular situation 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.
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 suggests that you consider amending your purchase order or other contractual agreements used in the transaction to require the vendor or supplier’s compliance with ISF requirements. Some importers are also adding conditions to financial instruments like letters of credit. Placing such language in your contractual documents could prove to be a mitigating 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 the ocean carriers, NVOCC’s and freight forwarders that participate in your import program. Meetings between your supplier base and the carrier(s) at origin should be implemented for purposes of ironing out new protocols and procedures for issuing the bill of lading number in advance. Most major ocean carriers (Maersk, APL/NOL, Evergreen, Hanjin, 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 offices engage problematic vendors or otherwise help you communicate this new requirement.
If your ISF baton is dropped between transfers, immediate disqualification may occur. Some importers 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 importers right now are the inability to get the bill of lading number in advance and/or lack of 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 polices or procedures, copies of other publications concerning ISF, and/or letters underscoring the importance and their support for the initiative from Senior Management.Our ISF direct filing customers are free to use our suggested language or some variation thereof for their company or particular situation 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.
Monday, August 24, 2009
Importer Security Filing Webinar
TRG Direct offers a self-filing application for importer security filing. Join us in a discussion on the new requirements and learn how you can decrease your costs and increase your control by brining this in-house. We will demonstrate our ISF software and show you how easily you can file an ISF.
Register for TRG Direct's upcoming ISF webinar series. Advanced registration is required and can be done by following the links below.
August 26th 11AM CT https://www2.gotomeeting.com/register/160213243
Sept 2nd 11AM CT https://www2.gotomeeting.com/register/553106835
Sept 16th 11AM CT https://www2.gotomeeting.com/register/723325202
If you are unable to attend one of the times above, please contact Jena Leary, 847-756-7553 or jleary@trgdirect.com to schedule a personlized consult.
Register for TRG Direct's upcoming ISF webinar series. Advanced registration is required and can be done by following the links below.
August 26th 11AM CT https://www2.gotomeeting.com/register/160213243
Sept 2nd 11AM CT https://www2.gotomeeting.com/register/553106835
Sept 16th 11AM CT https://www2.gotomeeting.com/register/723325202
If you are unable to attend one of the times above, please contact Jena Leary, 847-756-7553 or jleary@trgdirect.com to schedule a personlized consult.
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.
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