June 22, 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 third in a series of questions and answers to help familiarize you with ISF.
Frequently Asked Questions
Capture
1. What strategy do you have in place for arranging foreign counterparts at foreign ports?
UPS is closely evaluating our strategy for the ISF. We have engaged our counterparts in various countries around the world for input to ensure a smooth implementation. In part, our strategy will depend on the approach ultimately adopted by CBP.
2. Will there be a form that each manufacturing site needs to file before the carrier will pick up the goods?
Although not required, our anticipation is manufacturers will incorporate many of the data elements into the commercial invoice or attach an ISF worksheet. Ideally, this would be in addition to sending such data electronically to the submitting agent. We do not anticipate the ISF will need to be filed prior to the pick-up of the goods; however, the possibility could exist.
3. Will the shipper/manufacturer be required to provide all the new information on our commercial invoice?
Although not required, our anticipation is manufacturers will incorporate many of the data elements into the commercial invoice or attach an ISF worksheet. Ideally, this would be in addition to sending such data electronically to the submitting agent.
Data Elements
4. What elements are required at the line item level?
The HTS number, the country of origin, and the manufacturer’s (or supplier’s) name and address.
5. Do the 10 pieces of data have to be on one line?
CBP has not yet issued the record layout for the ISF. The projected time frame will be known shortly after the final rules are published.
6. We import embroideries which require dual classification codes. In this case, which classification do we use for the Harmonized Tariff Schedule (HTS) data element?
If we understand the question correctly, although CBP has not provided the data layout for the ISF, we assume it will be possible to file all tariff numbers for one ISF. We expect HTS numbers will be grouped by country of origin and manufacturer; however, we are not aware of any limitations on the number of tariffs provided for the ISF.
7. We buy many items from distributors who purchase fabrics around the world. They, in turn, ship the items to us using MID codes. It might be difficult to get the complete name and address of their supplier. Therefore, why can’t the MID codes be used since it has all the necessary information that is in their data base?
CBP has not provided a definitive reason MID codes will not be permitted. Our interpretation is CBP does not feel the MID codes provide accurate detailed information and are subject to change. Additionally, CBP realizes MID codes can be easily duplicated which makes it difficult to target specific entities solely based on MID codes.
8. Can multiple containers, countries, and tariff codes be on the same security filing (on the same master bill)?
Yes, the common denominator will be the house bill.
9. What is the “Consignee number(s)” that is part of the Importer Requirements?
CBP defines ‘consignee number’ as the Internal Revenue Service (IRS) number, Employer Identification Number (EIN), Social Security Number (SSN), or CBP assigned number of the individual(s) or firm(s) in the United States on whose account the merchandise is shipped. This element is the same as the ‘consignee number’ on CBP Form 3461.
Who assigns it?
This number is provided by various government agencies depending on the type of identifying number assigned to the consignee.