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CBP LA to Increase ISF Compliance Enforcement, CBP Tells LA Brokers Group

CBP's Los Angeles/Long Beach office started to use added enforcement measures to deal with non-compliance with Importer Security Filing (ISF) requirements, said a notice sent by the L.A. Customs Brokers and Freight Forwarders Association (LACBFFA). CBP will begin using holds on consolidated shipments for which there is no ISF on file 48 hours prior to the arrival, effective Oct. 7, said the LACBFFA notice. The LACBFFA said CBP's L.A. Director of Field Operations Todd Owen described the plans during a recent conference call with several trade associations in the area. CBP headquarters recently announced plans to ratchet up enforcement of ISF rules (see 13062613).

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The L.A./Long Beach CBP field office was previously using a more relaxed approach to the ISF enforcement by only requiring an ISF to be on file as of 24 hours prior to delivery, said the LACBFFA. The CBP field office was only placing holds on shipments that were on a "regular Straight Bill of lading and not on consolidated shipment," it said. That approach has worked and there's been a 50 percent reduction in shipment arriving without an ISF on file, said the LACBFFA. CBP didn't return a request for comment, likely due to the ongoing government shutdown.

CBP is now ready to "raise the bar for measuring the ISF's that are not on file by" requiring filing 48 hours prior to arrival, the notice said. CBP L.A. will also start placing holds on shipments for house bills of lading in consolidated containers, it said. "CBP will initially place a '2O' manifest hold on the container to show that the hold is an ISF hold," it said. "They will then allow a Permit to Transfer to move the container(s) to the consolidator’s Container Freight Station (CFS). The CFS’s at the ports are not automated with CBP for receiving manifest data that includes electronic holds and releases. CBP will have to send a manual hold in writing designating which house bill of lading must be held. The remaining house bills that did have the ISF on file timely will be released as under current practice."

That field office will also not necessarily designate consolidated containers held for ISF purposes as requiring a non-intrusive inspection (NII), it said. CBP will determine if an NII is required after the cargo is held at a CFS and may either inspect it at the CFS or a Centralized Exam Site, according to the LACBFFA.