Reminder: Comments on CBP's 10+2 Draft Proposal for Additional Advance Data Elements for Maritime Cargo Due by February 5th

CBP has stated the comments that will provide the most assistance will reference a specific portion of the draft proposal, explain the reason for any recommended change, and include data, information, or authority that support such recommended change. (See CBP notice for list of specific issues on which it is interested in receiving comments.)

Proposed 10+2 Data Elements and Sets

In late 2006, CBP issued a draft proposal¹ in order to facilitate its development of regulations to collect 10 additional commercial shipping data elements from importers or their agents and 2 additional data sets from ocean carriers (referred to by CBP as Security Filing data (SF)).

10 Proposed data elements from importers or their designated agents. In addition to the current data elements specified under the 24 Hour Rule for maritime cargo (19 CFR 4.7(a)), CBP proposes to require an additional set of 10 data elements 24 hours prior to vessel loading. These data elements would be linked, via the Automated Manifest System (AMS) or Automated Broker Interface (ABI) to the existing 24 Hour Rule data collected in the AMS. According to CBP, this portion of the SF would be required to be transmitted by the importer or its designated agent. (CBP also suggests that these 10 additional data elements would only be required for maritime cargo that is destined to remain in the U.S.)

These 10 additional data elements are:

• 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 (HTS) number (6 digit)

2 proposed data sets from ocean carriers. In addition to the data elements outlined above, CBP would require ocean carriers to provide two additional data sets to complete the security filing. These additional data sets would pertain to:

• Container status messages
• Vessel stow plan

Importer SF/Entry Data Requirements Could Both be Met Before Vessel Loading

Because of the similarity of the 10 SF data elements and entry data, CBP has previously stated that importers may be interested in fulfilling both SF and entry obligations at the same time by filing 24 hours before vessel loading. CBP stated that it will consider any comments in this regard within the context of existing statutory and technological capacity.

CBP Would Utilize Existing ACS Modules to Receive SF Data

In order to receive the SF data, CBP would utilize existing modules of ACS: the Automated Manifest System (AMS) or Automated Broker Interface (ABI). CBP is proposing that current authorized transmitting entities for these modules (i.e., ABI filers and AMS participants) may transmit the SF data. CBP has previously stated that it is committed to integrating this data submission process with the future ongoing development work and implementation of the Automated Commercial Environment (ACE).

¹ The draft proposal has also been referred to as a strawman proposal and a white paper.

(See ITT's Online Archives or 01/08/07 news, 07010805, for BP summary of CBP's request for comments. See ITT's Online Archives or 12/13/06 news, 06121305, for previous BP summary on CBP's 10+2 strawman proposal, which contains additional details.)

- comments due by February 5, 2007

- comments must be emailed to securityfilingstrawman@dhs.gov.

CBP's draft proposal available at http://www.cbp.gov/linkhandler/cgov/import/carriers/adv_data_elements.ctt/adv_data_elements.doc.

CBP's request for comments available at http://www.cbp.gov/xp/cgov/import/carriers/trade_overview.xml.