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.
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Thursday, July 23, 2009
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.
Thursday, June 11, 2009
Importer Security Filing for Carnets
A quick blurb on Importer Security Filing for Carnets
As of January 26th, 2009, if you have goods moving by ocean transport on a future carnet, or goods returning to the US on an already-issued carnet, you are required to make an Importer Security Filing prior to re-import into the U.S. The Importer Security Filing (ISF aka 10+2) requires certain shipment data to be provided to CBP 24 hours prior to the goods being loaded on the ship departing the overseas port and bound for the U.S.*
ISF Solution for Carnet Users:
Corporation for International Business offers an ISF Direct-Filing Module. Using the ISF Direct-Filing module will allow carnet holders to provide the required information directly to CBP for a modest fee, without using the services of an agent, Freight Forwarder or, Customs House Broker. Contact the ISF Carnet HelpLine at 877-227-6387 for additional information.
For more information contact the Corporation for International Business, a partner in TRG Direct.
As of January 26th, 2009, if you have goods moving by ocean transport on a future carnet, or goods returning to the US on an already-issued carnet, you are required to make an Importer Security Filing prior to re-import into the U.S. The Importer Security Filing (ISF aka 10+2) requires certain shipment data to be provided to CBP 24 hours prior to the goods being loaded on the ship departing the overseas port and bound for the U.S.*
ISF Solution for Carnet Users:
Corporation for International Business offers an ISF Direct-Filing Module. Using the ISF Direct-Filing module will allow carnet holders to provide the required information directly to CBP for a modest fee, without using the services of an agent, Freight Forwarder or, Customs House Broker. Contact the ISF Carnet HelpLine at 877-227-6387 for additional information.
For more information contact the Corporation for International Business, a partner in TRG Direct.
Thursday, June 4, 2009
Importer Security Filing Report Cards
It´s graduation day January 2010 where do you find yourself? Has U.S. Customs voted you valedictorian, a roll model to all ISF filers, or will you be sitting in the stands watching your colleagues receive their diplomas? If you haven´t been putting forth your good faith effort to file your ISF you will be starting back at square one fighting to catch up.
ISF Report Cards - Click here to see an example.
U.S. Customs is providing ISF report cards to importers who request them. This is to be used as an educational tool for reflection on the ISFs filed by the importer. Since we are still in a non penalty phase ISF filers should be using this report to understand the timeliness and accuracy of their filings. I suggest importers take of this offer to help yourself prepare for graduation. To register for your ISF report please send an email to U.S. Customs at progress_report@cbp.dhs.gov.
The email should include:
Filer´s corporate name
Filer code used for filing ISF
Point of Contact
Point of Contact´s telephone number
If you are a self filer, filing under another company's filer code, the ISF system administrators should have requested this on your behalf. There´s Still Time to Flip Your Tassel & Self FileI mporter Security Filing has been in effect for 4 months now. Many ISF self-filers have been filing ISF since day 1. There is still plenty of time to start filing before the penalty phase begins. Most systems can get you up and filing in less than 2 days. Whether you decide to direct file or not, you should weigh all your options. Just like choosing which college university to attend after graduation you want to pick the right option for you.
Pushing It - Advanced Placement Classes for ImportersNow that your filing your ISF you can save even more time and more money on your consumption entry. Using the same system to file both entries you can "push" the repetitive information from your ISF to your consumption entry. Systems like TRG Direct have added this ability to filter information for thier customers. Once you file your ISF in-house, why not file the shipment´s consumption entry as well?
ISF Report Cards - Click here to see an example.
U.S. Customs is providing ISF report cards to importers who request them. This is to be used as an educational tool for reflection on the ISFs filed by the importer. Since we are still in a non penalty phase ISF filers should be using this report to understand the timeliness and accuracy of their filings. I suggest importers take of this offer to help yourself prepare for graduation. To register for your ISF report please send an email to U.S. Customs at progress_report@cbp.dhs.gov.
The email should include:
Filer´s corporate name
Filer code used for filing ISF
Point of Contact
Point of Contact´s telephone number
If you are a self filer, filing under another company's filer code, the ISF system administrators should have requested this on your behalf. There´s Still Time to Flip Your Tassel & Self FileI mporter Security Filing has been in effect for 4 months now. Many ISF self-filers have been filing ISF since day 1. There is still plenty of time to start filing before the penalty phase begins. Most systems can get you up and filing in less than 2 days. Whether you decide to direct file or not, you should weigh all your options. Just like choosing which college university to attend after graduation you want to pick the right option for you.
Pushing It - Advanced Placement Classes for ImportersNow that your filing your ISF you can save even more time and more money on your consumption entry. Using the same system to file both entries you can "push" the repetitive information from your ISF to your consumption entry. Systems like TRG Direct have added this ability to filter information for thier customers. Once you file your ISF in-house, why not file the shipment´s consumption entry as well?
Thursday, May 21, 2009
TRG Direct Website Got a Makeover
TRG has been growing fast especially with the new Importer Security Filing regulations only 8 months away from implementation. With this quick growth TRG Direct decided to get a new look. The website design was done by 123 Triad, a company based in North Carolina. The look is modern and fun. But, don't let that fool you. The website is content rich with tons of useful information on importer security filing and direct filing.
Go check it out and let us know what you think. Maybe you'll like it so much you'll just have to start direct filing with us. Suggestions are always welcome. Soon enough the TRG website will be revamped too!
Go check it out and let us know what you think. Maybe you'll like it so much you'll just have to start direct filing with us. Suggestions are always welcome. Soon enough the TRG website will be revamped too!
Friday, April 10, 2009
Importer Security Filing & Your Good Faith Effort
10+2 Importer Security Filing has been under way since January 26th and U.S. Customs expects as an importer (of ocean cargo) that you are putting forward a "good faith effort" to file. A good faith effort can be defined in many ways. In this case you should be filing. Even though we are in a non penalty phase, filing now will help your company avoid the $5,000 non compliance penalty come Jan 26th 2010. The costs of filing this year will not compare to the costs of penalties next year.
So what has the industry been seeing?
The actual implementation of Importer Security Filing didn´t cause a much of a disturbance to those who put their best foot forward and filed away. What some importers did notice was that there were a few errors with matching the bill of lading. Yes, the bill of lading is required in order to match the importer´s ISF with the carrier´s ISF.A semi-tricky part to the entry is data collection. Making sure you have the information you need 24 prior to vessel lading.
How are importers filing?
Web-based ISF systems allow you to set up your vendors with certain rights in your account where they can actually enter their portion of the data. This makes it easier to collect everything you need and stores the information in the ISF until it ready to be sent to Customs for review. How do importers file?There are many programs available for importers to file their ISF. Not all but many are extremely economically priced. Systems such as TRG Direct offer a Web-based solution that doesn´t but an economic strain on companies who are learning how to file.
Search google.com and you will see just about every 10+2 ISF solution competitor. Simple research and a demonstration of the system will show you exactly which application is best for you. Maybe you don´t expect to file many ISF, let´s say less than 50 a year. In this case it probably is better to leave this to your U.S. Customs broker. Wait, as long as they aren´t charging you a heinous amount for each ISF or applying large set up fees. Because the truth is an ISF filing is not that difficult. Now that the industry has a taste of ISF, we see it´s really not so bad. That is as long as you aren´t over paying for this transaction.
So what has the industry been seeing?
The actual implementation of Importer Security Filing didn´t cause a much of a disturbance to those who put their best foot forward and filed away. What some importers did notice was that there were a few errors with matching the bill of lading. Yes, the bill of lading is required in order to match the importer´s ISF with the carrier´s ISF.A semi-tricky part to the entry is data collection. Making sure you have the information you need 24 prior to vessel lading.
How are importers filing?
Web-based ISF systems allow you to set up your vendors with certain rights in your account where they can actually enter their portion of the data. This makes it easier to collect everything you need and stores the information in the ISF until it ready to be sent to Customs for review. How do importers file?There are many programs available for importers to file their ISF. Not all but many are extremely economically priced. Systems such as TRG Direct offer a Web-based solution that doesn´t but an economic strain on companies who are learning how to file.
Search google.com and you will see just about every 10+2 ISF solution competitor. Simple research and a demonstration of the system will show you exactly which application is best for you. Maybe you don´t expect to file many ISF, let´s say less than 50 a year. In this case it probably is better to leave this to your U.S. Customs broker. Wait, as long as they aren´t charging you a heinous amount for each ISF or applying large set up fees. Because the truth is an ISF filing is not that difficult. Now that the industry has a taste of ISF, we see it´s really not so bad. That is as long as you aren´t over paying for this transaction.
Wednesday, January 7, 2009
Importer Security Filing: Two Birds One Bond
Importer Security Filing is fast approaching. By now you should be familiar with 10+2 filing requirements and have a plan in place to comply with U.S. Customs this coming January. Beyond the filing requirements what does this mean for U.S. Customs bonds?
After the one year informed compliance period of importer security filing ends, Customs and Border Protection will begin enforcing compliance in the form of liquidated damages. These damages will be $5,000 for each ISF violation.
Kill Two Birds With One Bond
Importer Security Filings will be secured with a continuous bond. The following bonds have been amended to cover these requirements. For the first year of implementation fines and penalties will not be assessed to the bond. An increase in the Customs bond is not required at this time. After CBP’s structured review of importer security filing bonding requirements may be amended.
◦ Import bonds
◦ Custodial bonds
◦ International Carrier bonds
◦ FTZ Operator bonds
CBP has also issued a new bond referred to as the Importer Security Filing bond. This continuous bond will also cover ISF entries.
Do You Still Import Using Single Entry Bonds?
Those importers who continue to import using single entry bonds will need to purchase the new continuous ISF Bond. TRG offers the most economical solution for Importer Security Filing to those companies importing under single entry bonds. Purchase one continuous bond to cover BOTH the ISF filings and the consumption entries.
TRG has created a presentation outlining 10+2 Importer Security Filing. Download your complimentary copy and stay informed.
TRG provides wholesale pricing on U.S. Customs bonds. By obtaining your import bond from TRG, you will benefit from a staff of experienced and knowledgeable administrators, underwriters, and customer service specialists to keep your bond accurate and in good standing with U.S Customs.
How do I Apply for a continuous U.S. Customs bond?
Contact Sarah Braun, at (847) 756-7531 or apply online at http://www.traderiskguaranty.com/
After the one year informed compliance period of importer security filing ends, Customs and Border Protection will begin enforcing compliance in the form of liquidated damages. These damages will be $5,000 for each ISF violation.
Kill Two Birds With One Bond
Importer Security Filings will be secured with a continuous bond. The following bonds have been amended to cover these requirements. For the first year of implementation fines and penalties will not be assessed to the bond. An increase in the Customs bond is not required at this time. After CBP’s structured review of importer security filing bonding requirements may be amended.
◦ Import bonds
◦ Custodial bonds
◦ International Carrier bonds
◦ FTZ Operator bonds
CBP has also issued a new bond referred to as the Importer Security Filing bond. This continuous bond will also cover ISF entries.
Do You Still Import Using Single Entry Bonds?
Those importers who continue to import using single entry bonds will need to purchase the new continuous ISF Bond. TRG offers the most economical solution for Importer Security Filing to those companies importing under single entry bonds. Purchase one continuous bond to cover BOTH the ISF filings and the consumption entries.
TRG has created a presentation outlining 10+2 Importer Security Filing. Download your complimentary copy and stay informed.
TRG provides wholesale pricing on U.S. Customs bonds. By obtaining your import bond from TRG, you will benefit from a staff of experienced and knowledgeable administrators, underwriters, and customer service specialists to keep your bond accurate and in good standing with U.S Customs.
How do I Apply for a continuous U.S. Customs bond?
Contact Sarah Braun, at (847) 756-7531 or apply online at http://www.traderiskguaranty.com/
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