trg customs bond holders learning about importer security filing

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If you haven’t started filing your ISF you risk being the first of importers to be fined a minimum of $5,000 in the first quarter of 2010! Importer Security Filing (10+2)

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Are You Prepared to Pay $5,000 per Importer Security Filing for Non-Compliance? With only 4 months left until Importer Security Filing penalties are issued, it’s time to make sure you are compliant. TRG has had many discussions with importers who believe they are in compliance, but in Customs & Border Protection’s (CBP) eyes, they are not. TRG is hosting a series of webinars free to our Customs bond holders to ensure they are in compliance. Anecdote: One of our ISF experts was on the phone with a TRG Customs bond holder last week. Prior to the meeting, the importer was convinced he was in compliance because he knew his broker was filing his ISF (the charge showed up on his bill). However, after reviewing his ISF progress report, we found out that his broker was filing the ISF after the ship had left. This will be a $5,000 fine come January for every ISF filed untimely.

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Page 1: TRG Customs Bond Holders Learning About Importer Security Filing

If you haven’t started filing your ISF you risk being the first of importers to be fined a minimum of $5,000 in the first quarter of 2010!

Importer Security Filing (10+2)

Page 2: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

ISF 10+2 Summary

Importer Security Filing, which you probably know as 10+2, is a Customs and Border Protection (CBP) regulation requiring importers and vessel carriers to provide advance data elements to CBP for non-bulk cargo shipments arriving into the United States by vessel. The focus of this initiative is to improve CBP’s ability to recognize high-risk shipments in advance to ensure the safety of America’s borders.

Page 3: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

On January 26th, 2010 CBP is requiring importers and carriers to transmit these additional data elements 24 hours prior to vessel lading.

Manufacturer Name & Address,

Seller Name & Address,

Container Stuffing Location,

Consolidator Name & Address,

Buyer Name & Address,

Ship to Name & Address,

Importer of Record #,

Consignee #,

Country of Origin of the Goods,

6 Digit Commodity #.

Importers (10)

Vessel Stow Plan, Container Status Message Data.

Carriers (2)

Data Elements

Page 4: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

Publication Date: November 26, 2008

Effective Date: January 26, 2009

Compliance Date: January 26, 2010 The 12 month period may be extended if

circumstances warrant. No liquidated damages assessed for not meeting

the new requirements No “do not load” (DNL) holds for compliance issues

Flexible Enforcement & Structured Review Period

CBP & Implementation

Page 5: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

Importers with no filing historycould be fined a minimum of

$5,000 in the first quarter of 2010.

Four factors may result in liquidated damages.

ISF Penalties

Failure to submit, Late submission,

Failure to update, Failure to withdraw.

Page 6: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

6 Mitigation Factors:

Progress of the importer’s ISF program, Percentage of ISFs containing violations, Tier 2 & 3 C-TPAT members will receive consideration up to

50%, Action taken by the importer after a violation has occurred, Circumstances beyond the importer’s control, Inaccurate info received by another party w/i the supply

chain.

Mitigation

Page 7: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

Anecdote: One of our ISF experts was on the phone with a TRG Customs bond holder last week.  Prior to the meeting, the importer was convinced he was in compliance because he knew his broker was filing his ISF (the charge showed up on his bill).  

However, after review of his ISF progress report, we found out that his broker was filing the ISF after the ship had left.  This will be a $5,000 fine come January for every ISF filed untimely.

Get Your Report & Review it Today!

Learn From Your Progress Report

Page 8: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

Page 9: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

Page 10: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

Your Next Steps

Get Your Report Card & Review

Make Sure Your Vendors Are Informed & In Compliance

TRG is Hosting Vendor Webinars

TRG has Suggested Notifications

Elevate ISF Internally

If you File More than 50 ISFs per Year Look into Direct Filing

Implement Policies & Procedures for Future Overseas Relationships

Page 11: TRG Customs Bond Holders Learning About Importer Security Filing

Only 4 Months to Compliance

Contact TRG

Gregg CummingsNational Sales Manager

Phone: 847-756-7543Fax: 847-756-7545Email: [email protected]