importer security filing presentation by trg direct from the cbp trade symposium
DESCRIPTION
This is a presentation by TRG Direct from the CBP Trade Symposium. Mike Laden, of TRG Direct gave this presentation at this year's CBP Trade Symposium. As January 2010 nears, Customs and Border Protection (CBP) continues to listen to the importing community to ensure the Importer Security Filing (ISF) system works as smoothly as possible. CBP has been hosting Outreach programs in several cities in order to answer questions and listen to concerns importers have about ISF. In these two-hour sessions, Rich DiNucci, Secure Trade Initiative director, starts by giving updates and then turns it over to three presenters: an importer, a software provider, and a broker or carrier. “Attendance has been good,” ISF software provider Mike Laden said. “Sold out both Chicago sessions. There has been no screaming, and it’s surprisingly not like a town hall meeting.” DiNucci’s relationship with Laden, TRG Direct president, has also allowed TRG Direct to give CBP constructive criticism about what Importer Security Filing issues importers have. For example, last month TRG Direct customers reported that ISFs were being Rejected due to invalid DUNS numbers. Laden reported the problem to DiNucci, who resolved the issue within days. Another ISF issue arose when TRG Direct filers discovered that entering the master bill of lading made it impossible for any other bill of lading under that master BOL to be transmitted to Customs. Since then, Customs has been able to stress the importance of entering the lowest bill number and has changed their system to differentiate between house and straight bills. CBP appreciates this type of feedback from importers and continues to improve the system. As of today, 2.8 million ISFs have been filed, and rejections are down to less than 2%. This is good news since Importer Security Filing carries heavy fines and penalties: $5,000 per error and up to $10,000 per ISF. Importers who file their ISFs with software providers like TRG Direct have had great success when they bring the process in house. Atalanta Corporation, who utilizes TRG Direct, achieved 99% level of compliance within three months of self filing.TRANSCRIPT
CBP Trade SymposiumWashington, DC
December 9, 2009
Background and History
• ATDI (Advanced Trade Data Initiative) the precursor to 10+2 – ISF
• Most US importers in the maritime domain know what they’re importing weeks or months in advance (Purchase Order)
• Clients successfully filing ISF since the program launched in January 2009
Trouble Spots and Challenges
• Bill not on file• Master bill containing multiple house bills; duplicate
ISF if filed against master• Some small importers do not pre-classify• Communications from China• Duns number rejects• Household + Diplomat = Diplomat• Don’t panic!
Change
• It’s a constant in our industry• Significant and alters the way things have
been done since the earliest days of shipping• Like its predecessor the 24-Hour Manifest Rule
many say, “It can’t be done”• CBP has been very responsive to issues
Importer Best Practices
• Communicate with all stakeholders• ISF expectations included into purchase orders,
contractual language (carriers and consolidators) and vendor payment terms
• NVOCC’s = Ensure automation and know what B/L has been transmitted in AMS
• Importer controlled and filed directly• Frequent review of ISF Performance Report
Importer Best Practices (continued)
• Some US importers allowing various levels of input at origin
• Record keeping 5 years• 60-90 days to debug the program depending on size
and supply chain complexity• Look for opportunities to improve and enhance – the
silver lining• Considering membership in C-TPAT to achieve
enhanced benefits
