June 23, 2008
Overview
The Importer Security Filing (ISF) initiative, also known as 10+2, is right around the corner.
Based on the proposed rule by Customs and Border Protection (CBP), U.S. importers must submit required security data electronically to CBP 24 hours prior to loading ocean containers on vessels destined for the U.S.
For additional information on ISF requirements, please visit the following web site: http://www.cbp.gov/xp/cgov/newsroom/news_releases/archives/2008_news_releases/jan_2008/01022008.xml
As your ISF agent, UPS will capture ISF information in a simple, compliant, and timely manner from both internal and external sources. Additionally, our solution will share data between our transportation and brokerage systems, submit data to CBP, and provide accurate and timely client visibility, messaging, and reporting.
Below are the second in a series of questions and answers to help familiarize you with ISF.
Frequently Asked Questions
Method
1. Is there a form that can be used for this security filing?
The ISF must be filed using either the Automated Manifest System (AMS) or the Automated Broker Interface (ABI). We anticipate the information will need to be provided on the actual commercial shipping documents or a separate form. The form would likely be provided by an agent who collects security data to file on the importer’s behalf. This may be accomplished through a revised Shipper’s Letter of Instruction, commercial invoice, template, separate form, or other method. We are not aware of CBP providing an official approved form. Ideally, this would be in addition to sending such data electronically to the submitting agent.
2. Should it be mandatory for importers to provide shippers HTS codes, duty and IRS numbers so this information can be included in their invoice, P/L and the rest of the shipping documents? Will the shipper need this information to give it to the carrier prior to departure for them to transmit to Customs in the AMS filing process? Is this the broker’s task?
Because the importer is responsible for the submission of ISF data, and the cargo will not be loaded on the vessel for export to the US until the ISF data is submitted and accepted, it's in the importer's best interest to streamline the communication of ISF elements to the agent as much as possible, whether the agent is a broker submitting through ABI, the forwarder or carrier submitting through AMS, or another party using either system.
The importer can achieve this by ensuring the agent has the data elements commonly known by the importer (see Importer Elements below), the seller (see Seller Elements below), and the forwarder (see Forwarder elements below) as early as possible. This can be accomplished by providing the importer's elements to the shipper to include on the commercial documents, or by sending the importer's elements to the agent directly.
Where possible, communication of the elements electronically from all parties to the agent will ensure the quickest receipt, processing, and submission by the agent to CBP.
Importer Elements
- Buyer (owner) name and address
- Ship to name and address
- Importer of record number / foreign trade zone (FTZ) applicant identification number
- Consignee number(s)
- Commodity HTSUS number (6-digit level required, 10-digit level optional)
Seller Elements
- Manufacturer (or supplier) name and address
- Seller (or owner) name and address
- Container stuffing location
- Consolidator (stuffer) name and address
- Country of origin
Forwarder Elements
- Master bill of lading number (MBL)
- House bill of lading number (HBL)
- Vessel name
- Lloyd's code
- SCAC code
- Container number
3. Re T&E shipments, our Mexico affiliate receives ocean shipments via Port of Long Beach and the shipment is moved in-bond to UPS-SCS Nogales, AZ for export to Mexico. Per the presentation, the booking party is the party paying for the transportation, which in our case is the U.S. location. Would COMPANY-US be shown as the booking party on the T&E entry or would it be COMPANY-MX? COMPANY-MX controls the shipment; COMPANY-US pays the bill.
According to CBP’s proposed rule, if the US party pays for the transportation of the goods, that party will be reported as the booking party.
4. UPS SCS handles our supplier management/freight forwarding and brokerage and has all of this information so I would assume this should not have a big impact on us. I would assume origin and brokerage will have to work together to have all 10 pieces of information filed on time. Is there a procedure being developed to ensure that this happens?
Yes, both transportation and the broker will work together to compile the needed information. Much of the information is already captured during the booking and customs clearance process, but there are new data elements that UPS will need to collect prior to submission.
5. How will this be addressed with shipments consolidated on a single master but under multiple house bills of lading?
CBP has indicated that ISF filing will be made at the HB level.
6. How will container stuffing location and consolidator name and address be communicated to UPS-SCS? If this information is added to the commercial invoice and provided to UPS-SCS at origin for export purposes, will the origin UPS-SCS location provide it to the UPS-SCS importing location? If so, what steps are being taken to ensure that the UPS-SCS importing location will receive it far enough in advance to meet the 24 hours before loading rule?
The container stuffing location and consolidator name and address may be provided to UPS by a variety of means – with the booking request, with the commercial documents, entered via web-form, etc. and may be provided by the shipper or any other party with knowledge of the facts. If received electronically or manually entered by our staff, this data will be routed electronically to the UPS team responsible for compiling all information, validating the data, and submitting to CBP. To ensure proper timing, the required information must be collected well in advance of intended container lading.