CBP Commissioner Expects SF "10+2" Advance Data for Maritime Cargo to Begin in Early 2008
During a speech at the recent Western Cargo Conference (WESCCON), the U.S. Customs and Border Protection Commissioner stated that new Security Filing (SF, 10+2) advance data requirements for imported maritime cargo are expected begin in early 2008 using a phased approach for implementation.
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(The SF is expected to consist of 10 additional data elements from importers 24 hours prior to foreign lading and 2 additional data sets from ocean carriers.)
60 Day Comment Period Expected on 10+2 Proposed Rule
Once the proposed rule is issued, the Commissioner expects there to be a 60-day comment period. Although he noted the proposed rule would be 'pretty much in final form,' other CBP sources stated that CBP would consider modifications during the comment period, as CBP expects to hear from a broader audience than those consulted during the proposed rule's development.
Penalties for Untimely, Inaccurate SFs Expected to be Noted in Proposed Rule
CBP sources also stated that SFs must be timely and accurate, and that certain penalty provisions are expected to be articulated in the proposed rule.
CBP Expected to be Receptive to Combining SF with Entry, Working on WCO Consistency
CBP sources additionally noted that CBP was receptive to combining the SF with the entry/entry summary, and that CBP was working on making SF consistent with the World Customs Organization's Framework of Standards to Secure and Facilitate Global Trade (SAFE Framework)1.
WESCCON Attendees Urge Trade to File Comments on Proposed Rule
Some WESCCON attendees characterized the SF requirement as having a large impact on the trade, and that the upcoming opportunity to comment on the SF proposed rule would be a "watershed opportunity."
(CBP has previously stated that the 10 additional data elements from importers would be in addition to the current data elements specified under the 24-Hour Rule. CBP also previously stated that the 10+2 data elements/sets would be linked, via the Automated Manifest System or Automated Broker Interface (ABI), to the 24 Hour Rule advance data collected in AMS.
CBP's earlier draft 10+2 proposal and a more recent set of Frequently Asked Questions, list and comment on the 10 additional data elements (that will be supplied by the importer or its designated agent:
- Manufacturer name & address (or supplier when manufacturer cannot be identified)
- 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
- Harmonized Tariff Schedule (HTS) number (6 digit, but 10 digit acceptable)
CBP's draft proposal had also stated that ocean carriers would provide two additional data sets to complete the security filing - the vessel stowage plan (48 hours after departure from the last foreign port, or for voyages less than 48 hours in duration, prior to arrival of the vessel at the first U.S. port) and container status messages.)
1In June 2006, the WCO Council adopted guidelines for the Authorized Economic Operator (AEO) program, as part of the SAFE Framework. The AEO system offers benefits for businesses that meet minimal supply chain security standards and best practices. CBP officials have previously compared AEOs to Customs-Trade Partnership Against Terrorism (C-TPAT) participants and industry sources have stated that AEO requirements are similar to those of C-TPAT.
(See today's ITT, 07101620, for BP summary on most recent version of the SAFE Framework.
See ITT's Online Archives or 01/08/07 news, 07010805, for BP summary of CBP's draft proposal on 10+2 for maritime cargo. See ITT's Online Archives or 02/13/07 news, 07021310, for BP summary of CBP's FAQ on its 10+2 draft proposal. See ITT's Online Archives or 03/08/07 news, 07030805, for BP summary of COAC's recommendations on CBP's 10+2 draft proposal. See ITT's Online Archives or 05/31/07 news, 07053105, for BP summary of CBP discussion of 10+2 at COAC meeting.)