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Curtis Spencer, President IMS Worldwide, Inc. imsw

10+2 When Do We Get The NPRM?. Curtis Spencer, President IMS Worldwide, Inc. www.imsw.com. CBP’s Advance Data Project. Required by § 203 of SAFE Port Act of 2006 Also known as “10+2” or the Security Filing Consists of 10 pieces of information filed by the importer and 2 from the carrier

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Curtis Spencer, President IMS Worldwide, Inc. imsw

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  1. 10+2 When Do We Get The NPRM? Curtis Spencer, President IMS Worldwide, Inc. www.imsw.com

  2. CBP’s Advance Data Project • Required by § 203 of SAFE Port Act of 2006 • Also known as “10+2” or the Security Filing • Consists of 10 pieces of information filed by the importer and 2 from the carrier • Applies to ocean freight only (for now) • Must be filed at least 24 hours prior to loading at foreign port • In addition to the currently required advance manifest data • See next page for the 10+2 elements

  3. DATA ELEMENTS • Data elements provided by the Importer of Record: • Manufacturer name and address • Seller name and address • Container stuffing location • Consolidator name and address • Buyer name and address • Ship to name and address • Importer of record number • Consignee number • Country of origin of the goods • Commodity Harmonized Tariff Schedule number (6 digit) • Data elements provided by the carrier: • Vessel Stow Plan • Container Status Messages

  4. Status of 10+2 • 10/06 – Legislation signed by President • 11/06 – Requested consultation from Commercial Operations Advisory Committee (COAC) • 2/07 – COAC submitted recommendations • 2/07 – Begin drafting Notice of Proposed Rulemaking (NPRM) in CBP • 8/07 – To DHS (almost out) • 9/07 – To OMB

  5. Status of 10+2 (cont.) • Next steps: • Final NPRM draft is at DHS, then to OMB • Complete cost/benefit and feasibility studies • Publish NPRM with 90 day comment period • Receive and analyze comments • Publish Final Rule in Federal Register • Implement program (see next page)

  6. Status of 10+2 (cont.) • Current status • NPRM nearly done in DHS • Cost/benefit and ATDI test program complete by time of NPRM publication • Estimated date of publication of NPRM: Late-Fall 2007 • No current discussions allowed with members of COAC or any other in the trade. • Do not know how many of the 37 recommendations were accepted (13??)

  7. Implementation Phase • First step: Trial using volunteer parties (not official but part of COAC recommendations) • Phase-in period of up to one year • Applies to everyone • Customs will use informed compliance approach to dealing with non-compliant filers • After phase-in period becomes mandatory, all data must be filed for all shipments

  8. Implementation Mechanics • Importer of record is responsible for filing • Can appoint agent (such as customs broker) to perform filing on its behalf • CBP will not regulate who is authorized • Still looking at 1 filer vs. 2 filers on same SF

  9. Implementation Mechanics • Data elements will be filed through ABI or AMS (or other, maybe) • Filers limited to importers, carriers and brokers or others who may qualify • COAC recommended filers be expanded to include foreign freight forwarders • Filing must be done by a single party • Information may be obtained from multiple parties

  10. Implementation Issues • Missing/incomplete/inaccurate data? • Amending the security filing • Issuing no-load messages • Unauthorized filers • Proprietary information • Cost/benefit & feasibility studies • “Customs business”? • Manufacturer not known • Consistency with WCO

  11. Some COAC Recommendations • CBP should issue electronic confirmation that filing has been accepted • Filing can be satisfied by filing CF7501 data or CF3461 data plus 2 elements • Time period for filing entry be pushed back to any time after departure from last port • CBP should identify exempt transactions • Importer should have ability to view filings on its behalf on-line • COAC must remain engaged during development and deployment stages

  12. More COAC Recommendations • CBP should issue electronic confirmation that filing has been accepted • Filing can be satisfied by filing CF7501 data or CF3461 data plus 2 elements • Time period for filing entry be pushed back to any time after departure from last port

  13. More COAC Recommendations • CBP should identify exempt transactions • Importer should have ability to view filings on its behalf on-line • COAC must remain engaged during development and deployment stages

  14. More COAC Recommendations • CBP will accept “filing of the 214” in place of entry, entry summary on all such suggestions • Time of filing amendment will be prior to entry “or admission” • COAC to review second “straw man” prior to NPRM (not accepted!) • Cost-benefit analysis to use industry best practices, prior to NPRM

  15. Conclusion? • 10+2 will be the 24-hour rule, on steroids!! • The issue of “single filer” may become contentious and a real issue • Timing of the data needed is key to multiple filers • Watch for the “hammer” at the 13th month • This is a “paradigm shift” for the importing community • Experts agree: 2-3 days delay in the supply chain

  16. Questions & Answers Curtis Spencer, President IMS Worldwide, Inc. www.imsw.com

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