CBP Update on 10+2: C-TPAT Importer Report Cards, Flexibility, and Unified Entries
During the May 6, 2009 Departmental Advisory Committee on Commercial Operations of U.S. Customs and Border Protection and Related Homeland Security Functions (COAC) meeting, Richard DiNucci, Director of CBP's Secure Freight Initiative, provided an update on 10+2.
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The following are highlights of his comments:
ISF Report Cards Expected to be Emailed on May 10th
DiNucci stated that Importer Security Filing (ISF) "performance report cards" (aka progress reports) are expected to be sent out on Sunday, May, 10, 2009 via email to ISF filers who registered to receive them.1
ISF Report Cards Will Also be Sent to C-TPAT Importers
DiNucci announced that the report cards would also be sent to Customs-Trade Partnership Against Terrorism (C-TPAT) importers within the next 30 days. He expects them to first be delivered to Tier 3 importer partners, than Tier 2, and finally Tier 1.
Penalty Mitigation Guidelines Should be Out Soon
DiNucci added that the 10+2 penalty mitigation guidelines should be released within the next few weeks.
Updated 10+2 Statistics
DiNucci also provided the following updated 10+2 statistics:
Flexibility option rarely used. The trade is using the flexibility option for the six "flexible" 10+2 data elements less than 1% of the time. (CBP's interim final rule provides flexibility for the following data elements: manufacturer (or supplier), ship to party, country of origin, commodity Harmonized Tariff Schedule (HTS) number, container stuffing location, and consolidator (stuffer).)
Few unified entry filings. 3 - 5% of ISFs are unified entry filings (when the ISF-10 and entry are filed via the same electronic transmission).
Over 720,000 ISFs received. As of May 6, 2009, CBP has received 720,000 ISFs and the number is rising on a weekly basis. There are approximately 1,300 individual ISF filers.
Reject rates, etc. 5 - 6% of ISFs are rejected each day and the error rates continue to decrease (DiNucci noted that while there are rejections daily, shipments are not being held; the trade is receiving the reject messages for informational purposes.) 4 - 5% of ISFs are accepted with conditions and approximately 90% of ISFs are accepted without conditions.
1CBP officials at the recent National Customs Brokers and Forwarders Association of America's annual conference stated that the report cards were scheduled for release at the end of April.
(See ITT's Online Archives or 04/27/09 news, 09042705, for BP summary of CBP officials providing a 10+2 update at the recent NCBFAA conference.
See ITT's Online Archives or 12/23/08 news, 08122310, for the final part of BP's summary on the details of CBP's 10+2 interim final rule, with links to previous parts.
See ITT's Online Archives or 03/10/09 news, 09031015, for the final part of BP's summary on CBP's 10+2 FAQ, with links to previous parts.)