CBP Expects to Issue 10+2 Single Transaction Bond Requirements Soon, Etc.

The following are highlights of their comments:

ISF Single Transaction Bond Requirements Expected "Soon"

ISF Single Transaction Bond (STB) requirements are expected to be issued soon. STBs would be processed at the port of entry and CBP is working on the technical issues to allow their processing.

With regards to STB minimum bond amounts, CBP may not provide instructions to the trade on the minimum bond amount they should have. Instead, officials suggest that the trade look at the mitigation guidelines to see what the potential penalty assessments could be before getting a STB. (See ITT's Online Archives or 07/17/09 news, 09071705 for BP summary of mitigation guidelines.)

(CBP had stated in its February 2009 FAQ on 10+2 that bonds will not be required for ISF purposes until January 26, 2010, but are allowed before then. Activity Code 1, 2, 3, or 4 continuous bonds or a stand-alone ISF continuous bond are acceptable. CBP also stated that the requirements for filing STBs for ISFs were being discussed with the trade. See ITT's Online Archives or 02/11/09 news, 09021115, for BP summary.)

Updated 10+2 Statistics

CBP provided the following updated 10+2 statistics:

Timeliness. Using the first bill of lading filing dates, ISFs were timely 47-48% of the time.

(BOLs are often filed several days in advance of actual vessel lading; therefore, some of the "untimely" ISFs are actually timely. CBP previously stated that it will use the "vessel departure date" in addition to the first BOL filing date to better assess ISF timeliness. These two reference dates are merely used as indicators of timeliness.)

Over 1.8 million ISFs received. In total, CBP has received over 1.8 million ISFs (this includes those ISFs not timely filed or inaccurate). CBP has also received approximately 3,300 stow plans and 53 million container status messages.

17,000-18,000 ISFs/day being received. CBP is receiving 17,000-18,000 ISFs per day. Officials added that this number is a good representation of the entries that are being filed. (In the spring they were receiving 10,000-12,000 ISFs per day.)

2-3% reject rate. The reject rate for ISFs is 2-3%. CBP noted that when the updated ISF transaction sets were implemented, there was a spike in the reject rate. However, the reject rate has come back down to 2-3%.

(On July 12, 2009, CBP implemented the changes contained in the "pending release" ISF transaction sets for the Automated Broker Interface and the Automated Manifest System. See ITT's Online Archives or 07/27/09 news, 09072705, for BP summary announcing that CBP implemented the modified ISF transaction sets.)

1,600 unique filers, 70,000 IORs. There are approximately 1,600 unique ISF filers and 70,000 unique Importers of Record (IORs) identified as ISF importers.

CBP Currently Conducting "Second Round" of Outreach Events

CBP is currently conducting the "second round" of its outreach events that will be held in various locations around the country to provide the trade community with an opportunity to learn more about the 10+2 interim final rule.

(See ITT's Online Archives or 08/19/09 news, 09081935, for BP summary of CBP's updated outreach event schedule.)

CBP Issued Outreach Brochure Aimed at Informing Small & Medium Firms

CBP has issued a 10+2 brochure entitled "Importer Security Filing and Additional Carrier Requirements." The brochure, which is available on CBP's website and is to be available in hard copy at the ports, is part of its outreach aimed at informing small and medium size firms on the interim final rule's requirements. The publication provides an overview of the program, describes individual responsibilities under the rule, lists what information should be filed, addresses rule enforcement, and offers sources for additional information.

(Brochure, dated August 2009, available at http://www.cbp.gov/linkhandler/cgov/newsroom/publications/trade/import_sf_carry.ctt/import_sf_carry.pdf)