ISF Day of Reckoning Arrives
It's safe to say that if your company is not filing the mandatory Importer Security Filing (ISF) for all maritime cargo bound for the US by today, that you can expect difficulty getting your shipment(s) released upon arrival in the U.S.
For more information on ISF filing and the most comprehensive easy-to-use system for filing ISF's and customs entries at a savings of up to 90% off ordinary costs please contact TRG Direct.
TRG Direct President Michael Laden has been very active attending CBP ISF Public Outreach Sessions at various venues around the country and in Europe. TRG Direct has been instrumental in working closely with CBP to ensure that all problematic system issues are addressed and remedied during this critical non-enforcement phase.
Showing posts with label isf self filing. Show all posts
Showing posts with label isf self filing. Show all posts
Monday, February 22, 2010
Tuesday, January 19, 2010
Richard DiNucci Attends TRG Direct User Group
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.”
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.”
Friday, January 8, 2010
The ISF Honeymoon Comes to an End Jan 26th
The ISF Honeymoon Comes to an End January 26th
The honeymoon phase of Importer Security Filing (ISF) will be over in less than one month. On January 26th, 2010, U.S. importers of ocean cargo will be faced with a harsh reality. Customs and Border Protection (CBP) will begin issuing fines and penalties for importers who fail to file their ISFs, file late, fail to update, or fail to delete their ISFs. Penalty amounts will be $5,000 per Importer Security Filing transmission and can be as much as $10,000 per ISF.
Was your honeymoon successful? Are you ISF ready?
At this time, importers need to be very familiar with their progress reports. Customs issues these monthly progress reports to whoever is filing the ISFs in order to let them know how they are doing. The reports inform the filer about how often their ISFs are accepted or rejected as well as how timely they are filing. If you haven’t seen your progress report, you need to ask whoever is filing immediately. Remember: it is not the filer that has to pay the fine; the importer is liable for their ISFs.In order to avoid paying these stiff fines, many importers have brought their policies and procedures in house to ensure they know that they are filing timely and accurately.
The ISF consists of 10 very easily attainable data elements. Once the importer begins receiving the information, the filing is easy.It's time to create a successful ISF program.TRG Direct, an ISF and customs entry self filing provider, allows importers to file online in seconds using templates and excel uploads. Also, since the ISF is not considered customs business, many importers allow their vendors to access the ISFs under their own user names and input information, which means the information never has to go through a third party.If you haven’t started filing, don’t stress: you still have a month to practice filing penalty-free. However, you need to start filing now. CBP has stated that the most important thing importers can do before compliance begins is to create a history with CBP by filing their ISFs. By doing so, importers may be able to mitigate any fines and penalties assessed at the beginning of compliance. Importers who have not been filing will be the first ones paying these fines.If you have been filing, you need to make sure your policies and procedures are in place and that all filings are timely and accurate. Check your progress report to see how well you’re doing. And remember, by filing yourself, you have complete control over filing timely and accurately.
The honeymoon phase of Importer Security Filing (ISF) will be over in less than one month. On January 26th, 2010, U.S. importers of ocean cargo will be faced with a harsh reality. Customs and Border Protection (CBP) will begin issuing fines and penalties for importers who fail to file their ISFs, file late, fail to update, or fail to delete their ISFs. Penalty amounts will be $5,000 per Importer Security Filing transmission and can be as much as $10,000 per ISF.
Was your honeymoon successful? Are you ISF ready?
At this time, importers need to be very familiar with their progress reports. Customs issues these monthly progress reports to whoever is filing the ISFs in order to let them know how they are doing. The reports inform the filer about how often their ISFs are accepted or rejected as well as how timely they are filing. If you haven’t seen your progress report, you need to ask whoever is filing immediately. Remember: it is not the filer that has to pay the fine; the importer is liable for their ISFs.In order to avoid paying these stiff fines, many importers have brought their policies and procedures in house to ensure they know that they are filing timely and accurately.
The ISF consists of 10 very easily attainable data elements. Once the importer begins receiving the information, the filing is easy.It's time to create a successful ISF program.TRG Direct, an ISF and customs entry self filing provider, allows importers to file online in seconds using templates and excel uploads. Also, since the ISF is not considered customs business, many importers allow their vendors to access the ISFs under their own user names and input information, which means the information never has to go through a third party.If you haven’t started filing, don’t stress: you still have a month to practice filing penalty-free. However, you need to start filing now. CBP has stated that the most important thing importers can do before compliance begins is to create a history with CBP by filing their ISFs. By doing so, importers may be able to mitigate any fines and penalties assessed at the beginning of compliance. Importers who have not been filing will be the first ones paying these fines.If you have been filing, you need to make sure your policies and procedures are in place and that all filings are timely and accurate. Check your progress report to see how well you’re doing. And remember, by filing yourself, you have complete control over filing timely and accurately.
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.
Tuesday, November 3, 2009
ISF Software User Group Meeting
TRG Direct's next ISF software and direct filing system User Group webinar will be on November 11th at 11am CT.
To register for the webinar please visit: https://www2.gotomeeting.com/register/300758194
Our webinar is open to our self filing importers as well as prospects looking further into our system. Please mark this on your calendar and plan to attend. Great information comes out of these events!
To register for the webinar please visit: https://www2.gotomeeting.com/register/300758194
Our webinar is open to our self filing importers as well as prospects looking further into our system. Please mark this on your calendar and plan to attend. Great information comes out of these events!
Friday, September 18, 2009
Help! ISF Vendor Compliance Program
Calling all TRG Direct ISF self-filers! We are hosting a series of vendor compliance webinars to engage them in ISF.The webinar will include
A background on ISF
An in depth look at the 10 elements,
US Importers &contractual relationships
A vendor’s role in the Importer Security Filing
Processes as a supplier
Questions & Answers
Calling all TRG Direct ISF self-filers! We are hosting a series of vendor compliance webinars to engage them in ISF.The webinar will include A background on ISF, An in depth look at the 10 elements, US Importers &contractual relationships A vendor’s role in the Importer Security Filing Processes as a supplier, Questions & Answers.
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