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U.S. National Security Import Controls: Electronic Compliance Systems: 10+2 Importer Security Filing (ISF)
What is the Importer Security Filing 10+2 Program?
How do Importer Security Filing filers get signed up for the ABI system?
Will CBP create a web portal in ACE so Importers can file their own Importer Security Filings?.
Will Custom House Brokers (CHBs) have the ability to query ISF performance reports from I track / Ace Portal?
If we hire a customs broker to be our agent, do they have to be our agent for all of our ISF
Can we use different agents for different filings? Can our agents use both AMS and ABI to do our filings? Will this affect our filings in any way?
How will an importer demonstrate to CBP that they are making 'satisfactory progress towards compliance?'
Will CBP provide feedback from the system to the importers / agents for ISF filing timeliness and/or accuracy?
For a unified entry filing, if the entry is rejected will the ISF filing be automatically rejected as well?
For a unified entry, when do duties have to be paid?
I have a question on how the unified filing is going to work under the ISF. Many of our shipments are sent in-bond from the unlading port to the port of entry.
If cargo is refused admission by a foreign country after having been exported from the U.S. and the cargo has not left the custody of the carrier or the foreign customs service, will such cargo require an ISF?
If a container is loaded on a vessel in the U.S. and goes foreign but is not unladen until it returns to the U.S., what are the ISF filing requirements?
What are the importer
Will CBP require a 'special' and separate power of attorney (POA) for ISF purposes? Currently, brokers use a generic POA that includes broad agency language for all importing activities, including customs brokerage and forwarding if applicable. CBP should accept the current POA used by brokers.
During the flexible enforcement period the lack of a postal code will result in an 'accepted with warnings' message. Is CBP expecting an update to the ISF for
How do I find information about any public outreach efforts in regards to the new Security Filing?
If an importer uses multiple CHBs can the importer select one broker to do an ISF and another to make entry (on the same shipment)?
If my system will not be ready until April or May of 2009 should I get a third party to file my ISF?
Does the ISF Filer need to be located in the U.S.?
Does the 'filing agent' for the importer have to be a Licensed Customs Broker?
What is the process for nominating a service center for ISF 10+2 filing?
There are instances where no SCAC code exists. Will there be a CBP assigned number and, if not, which identifier will be used in the service center nomination letter?
If the service center nomination comes from an assigned ISF agent, does a separate notification need to be sent for each customer they have been nominated by?
When do we have to stop amending the ISF?
Are changes to the ISF after arrival at the port of discharge allowed or required?
What happens if I fire my ISF Agent, but still need to update my ISF?
How will importers be able to amend the security filing if they don't have access to the Importer Security Filing elements in CBP systems?
What happens if I enter an ISF and then the shipments do not ship?
Will you allow the entry to update the ISF?
How do ISF Filers get signed up for the AMS system?
Is a bill of lading number required at the time of an ISF filing?
Please advise what to do if you do not have a bill of lading number at the time you submit the ISF. Most times the bill of lading numbers are not issued until after sailing.
If the NVOCC is a non-AMS participant, should we file the master bill of lading instead of the house bill of lading with the ISF?
When will the bonds, including the stand alone ISF bonds be required? January 26, 2009 or January 26, 2010? Can we file ISFs during the delayed compliance period without obtaining a bond first?
. If an agent allows his bond to be obligated, is he considered the ISF Importer with all of the liabilities associated with the ISF filing?
Can a single transaction bond be utilized for the ISF filing? If a broker does not have a continuous bond and the importer does not have a continuous bond how will a bond for ISF be filed?
Does an importer have to have the ISF stand-alone bond to be an ISF Importer?
Under what circumstances will CBP require or allow the new ISF stand alone Continuous Bond in lieu of an Activity Code 1, 2, 3, or 4 Continuous Bond, or single transaction bond?
How will the limit of liability be determined for an ISF single transaction bond?
As single transaction bonds for entry require a paper submission to CBP, how will an ISF single transaction bond be matched to an electronic ISF filing?
Will CBP accept one bond for the ISF filing and a second bond for entry? Is this true for a continuous bond as well as Single Transaction Bonds?
. If a combined entry & ISF filing is sent, does the importer bond obligated on the entry cover both the entry and the ISF? Is this true for both continuous bonds and Single Transaction Bonds? If so does the limit of liability remain the same as it is now?
How will ISF bonding requirements be determined when the value of the cargo is unknown?
Will CBP accept a single transaction bond for $5,000 for an ISF filing for personal effects and/or other shipments such as carnets?
The Interim final rule states 'CBP will enforce the importers security filing, vessel stow plan, and container status message requirement, through the assessment of liquidated damages, in addition to penalties applicable under other provisions of law.' Can you give us an example of the types of penalties you had in mind in this regard. (Reference: 71760 - 3rd column, 3rd paragraph)
How does the agent agree in writing to allow its bond to be used for an importer who doesn
The Interim Final Regulations provide that every ISF Filer/Importer must have a Basic Importation Bond under which the principal agrees to comply with the new provisions of part 149.
. Additions to bond regulations for type 1, 2, 3, and 4 (19 C.F.R.
Will you consider how to apply liquidated damages if two filings have been done and where one is correct and the other one is incorrect?
Will the Bond tie to the entry or will they have to have a Bond for Security Filing and a Bond for entry?
Given the potential for rapid and substantial accumulation of liability, will CBP consider a prohibition or limit on customs brokers posting their bond(s) to secure the ISF?
When is the final draft of this new bond expected?
Are these 'new' and separate bonds expected to be used primarily for single entry bond importers (this is what we suspect)?
If the importer does not have a bond, can the filer obligate its own bond?
Will an import bond rider be required to fulfill the regulatory changes required in the ISF rule?
What is the process of notifying CBP that a bond is actually on file?
. Is my current continuous bond sufficient to file an ISF?
Can the custodial bond (Type 2) be used for all of the ISF requirements?
Can I use an FTZ bond to file an ISF for a shipment that is not being entered into an FTZ?
I do not have to secure my informal entry with a bond today. Will CBP provide for any exemptions to the bond requirements for the ISF?
Existing rules exempt bulk and certain break-bulk cargoes e.g. most forest, steel products from the 24 hour requirements.
It appears that the regulations do not apply to bulk shipments (petroleum, etc).
My question is regarding break-bulk cargo, specifically Chilean produce.
Does this new rule engage the
I am curious as to how containerized import shipments traveling under a carnet are to be handled in regards to Commodity HTS numbers. Goods shipped under a carnet are required to be described on the General List, which is part of the carnet, but does not require the application of HTS numbers. When the final rule is ultimately in effect, will carnet goods now require classification pre-shipment?
Who do we contact at CBP if we are having system problems?
I noticed there are several 'types' of security filings. Which one should I use?
Can CBP please explain in more detail how household goods and personal effects shipments can be handled? I act as an agent for several hundreds of these shipments per month. Typically, these shipments are on one bill of lading and are co-loaded in the same container. Can I provide my own IRS# as the 'Importer of Record#' as long as I provide my clients information in the 'Consignee#' field?
How do I handle shipments sold on the water?
Will any of the new data that is being submitted be considered to be part of the carrier 'manifest' and thereby become public record? Does CBP have a form that can be filled out to request confidentiality of ISF information?
Will the importer have access to carrier
What type of assistance will CBP provide the trade to help us through this new process? Will there be a phone number available for general help?
How do you know that the repaired container will eventually be scheduled for the U.S.?
Are ISFs required for non bulk cargo carried on a passenger vessel?
Are vessel stow plans required for passenger vessels?
In many of our transactions, a single entity may be the same for several of the different required ISF elements. For instance, the 'Seller (Owner) Name and Address' might be the same as the 'Manufacturer (Supplier) Name and Address'. Likewise, the 'Buyer (Owner) Name & Address' might be the same entity as the 'Importer of Record Number'. Is it ok to repeat the same information if the entities are the same?
Can the importer of record number be a CBP assigned number?
What identification number is required for parties without U.S. social security numbers shipping household goods?
Can a foreign entity be identified as the Importer of Record Number?
What identification number is required for parties without U.S. social security numbers shipping household goods?
The ISF-10 record asks for a Consignee. According to the ISF Implementation Guide, for unified entry, the EI-10 record is used to report
If the container has to be devanned in more than one location (i.e. container does multiple stops after arriving in the US and drops cargo off at each location), does 10+2 require listing of all locations for the ship to addresses?
Who should be listed as the 'Ship to Party' when a shipment is shipped to a distribution facility that is owned by one company and operated by another related company?
Full container load (FCL) cargo clears prior to arrival at the port of discharge.
FCL cargo moves in-bond to an inland point by rail. After clearance at the inland port, the container is delivered to the ultimate consignee.
FCL or LCL cargo moves on a PTT to a CFS warehouse for transloading to trucks for delivery.
We import containers with thousands of parts, potentially having literally hundreds of different manufacturers, from a related party who, in turn, purchases the parts from those manufacturers. These parts may be commingled prior to importation. On the ISF filing, can we provide the identity of our related party to fulfill the Manufacturer (Supplier) ISF requirement as this is the party from whom we actually buy the parts or do we need to list all the manufacturer's individually?
Please advise if we need to submit both the manufacturer and the supplier info on the 10+2 ISF filing. Or, will the supplier data be sufficient?
Can the manufacturer (supplier) be a U.S. company?
If the merchandise is assembled in one country, but parts are from many other countries which country of origin do I list?
Can you advise if the country of origin needs to be linked to each Harmonized Tariff Schedule of the United States (HTSUS) number or is it enough that the data is given electronically against each part number?
When you talk about line-item linking requirement are you talking at the HTS 6 digit level or at a SKU level on the commercial invoice from the manufacturer/supplier? I am asking as we have shipments from one manufacturer/supplier that might contain a 100 different SKUs but would only result in five of HTS numbers.
Parts: If an importer of parts brings in container loads of thousands of parts with multi manufacturers, country of origin, and Harmonized Tariff Schedule of the United States (HTSUS) numbers, do they upon filing the ISF have to show every part HTSUS number or can they show a general number such as 8714.190060 which is parts and accessories of motorcycles? The exact parts in the shipment may not be known upon filing the ISF and since 8714.190060 is specifically parts and accessories of motorcycles is it acceptable?
FROB: How many HTS digits are required for foreign cargo remaining on board (FROB)?
Regarding the Container Stuffing Location and Consolidator (Stuffer) (the 2 data elements that are to be filed as soon as possible, but no later than 24 hours prior to arrival)
If a single container is stuffed in multiple locations, can I enter all locations into the ISF?
The interim final rule states that for break bulk cargo the Container Stuffing Location should be the party that made the goods 'Ship ready.' This term is somewhat vague when it comes to the shipping of motor vehicles on ro-ro vessels. Does 'Ship ready' refer to the preparation for transport of the vehicle such as the application of protective tape and suspension blocks or does it refer to the actual movement onboard the vessel and lashing of the vehicle?
I need a simple way to explain what Container Stuffing Location & Consolidator (Stuffer) mean to my foreign shippers.
An export shipment is loaded into a container at a facility in Germany in which the brick and mortar, as well as the goods in the facility, are owned by Company AG. However, the facility is operated by a related firm, Company AG Logistics Services. Who would be listed as the 'Container Stuffing Location' for the ISF? Company AG or Company AG Logistics Services?
Regarding the Container Stuffing Location and Consolidator (Stuffer) (the 2 data elements that are to be filed as soon as possible, but no later than 24 hours prior to arrival)
If there are multiple stuffing locations and there are multiple consolidators do all consolidators need to be listed? An example would be an NVOCC doing a milk run where it stops at multiple locations and the container is stuffed at each location by a different party. Would all stuffers need to be listed for just the party who ARRANGED for the stuffing?
For a 'Shipper Loaded' Container that is shipped by a manufacturer directly with the steamship line, who would be shown as the Consolidator or Stuffer?
Foreign port of unlading' is defined as the port code for the foreign port of unlading at the intended final destination. How should a location be reported when the location is not a port or when there is no port code associate with the destination?
Will CBP issue any do not load (DNL) messages during the initial flexible enforcement period?
If CBP issues a DNL for the ISF, how will the carrier know if it was because the ISF or manifest?
Can there be multiple violations on one ISF?
Will CBP issue a liquidated damages case beginning January 26, 2009 if the importer does not file an ISF?
Will CBP issue a liquidated damages case beginning January 26, 2009 if the importer files an incorrect ISF?
Existing rules exempt bulk and certain break-bulk cargoes (e.g. most forest and steel products) from the 24 hour timing requirements of the 24 Hour Rule.
Are ISO tanks exempt from the ISF Requirements?
Are 'containerized bulk' shipments exempt?
Is the flexibility (i.e. acceptable range of responses) only for the flexible enforcement period or is it CBP's intent to keep the flexibility in the filing after the flexible enforcement period expires?
CBP will not assess liquidated damages for ISF violations during the 12-month structured review and flexible enforcement period. Is this also true for carriers
Will CBP issue do not load (DNL) messages solely for failure to comply with the ISF requirements during the flexible enforcement period?
Can you provide a list of all the widely recognized commercially accepted identification numbers for the ISF entities such as the buyer, seller, etc.?
Will CBP provide query functionality for DUNS numbers?
The flexible enforcement period ends on January 26, 2010. Will CBP begin assessing liquidated damages for ISF violations for cargo that is arriving within the limits of a port in the United States by January 26, 2010, or is it for cargo that is laden foreign on January 26, 2010?
Will bonds be required on January 26, 2009, or January 26, 2010?
Are ISFs required for informal shipments?
. Are ISFs required for U.S. military household goods shipments?
Are bonds required for ISFs for U.S. military household goods shipments?
For U.S. military household goods, can the moving company contractor be the ISF Importer?
Are
For U.S. goods returned, should the HTSUS Chapter 98 number or the HTSUS commodity number be provided?
. For U.S. goods returned, can the manufacturer (supplier) be a U.S. company?
Can an ISF cover more than one vessel and voyage?
Is there going to be a paper ISF Form?
Since manifested quantity is not a part of the ISF filing, how will CBP handle multiple ISFs for one bill of lading?
Can bills of lading on the same vessel and voyage for the same importer be combined in the same ISF if the ports of loading or discharge are different?
It is possible to transmit one ISF for multiple bills of lading on the same vessel for one importer if they are one shipment.
The question now is does the word 'shipment' mean entry as in example one?
We currently use a broker to file our entry documents via the ABI interface.
I am a small importer that rarely brings in a whole container; most shipments are a few pallets or boxes.
Pursuant to the new regulations, some ISF elements must be submitted no later than 24 hours before the cargo is laden aboard the vessel at the foreign port. When cargo is first laden aboard a feeder vessel, are these elements required no later than 24 hours before the cargo is laden aboard the feeder vessel or the vessel destined to the United States? When are ISFs for FROB required?
On the I.E.
Who is the responsible party for filing an ISF-5 for FROB? Who is responsible for filing the ISF-5 for IE and T&E shipments?
Are imports into Puerto Rico (ocean shipments from non-US locations) subject to ISF/10+2 filing requirements?
Are ISFs required for goods arriving in the U.S. via rail or truck? Will I need to do the ISF filing if my cargo will not be on a vessel until the point it is leaving the United States?
What if I am the ISF Importer at the time the ISF was filed and I no longer want to take responsibility for the shipment?
How can an importer be responsible for an ISF if they are not aware of a shipment?
Can a foreign entity be the ISF Importer?
Can the NVOCC file an ISF even though there is no legal requirement to do so?
If the VOC is the ISF Importer for FROB, does this mean the VOC is required to be the ISF filer for T&E and I.E. cargo?
We currently handle some shipments that move to an inland port on the ocean liner
When an ISF is transmitted to CBP by a Customs broker through ABI and a response received back to the Filer, how will the carrier know it is okay to load the shipment? Will the carrier get a message?
Can the ISF Importer provide the ISF unique identification number to the AMS notify party for shipments where the ISF has been matched to the manifest?
Will CBP provide feedback when the ISF is filed?
Does the unique ID become part of the entry package?
Will CBP return a unique identification number for a unified manifest ISF-5 filing?
Is CBP expecting an update to the ISF for
If my initial ISF is rejected can I simply amend it or must I create a new one?
Can I receive a unique transaction number for my rejected filings in order to 'prove' that I attempted to submit an ISF?
The status advisory message confirming a match (or no match) with the bill of lading is to be sent to the ISF filer. If there are two filings against the same bill of lading, do both filers receive the status advisory message?
How will CBP prevent/handle duplicate filings? Will the confirmation provide an indication of duplicate submissions if the ISF is already on file?
Can the MID number be used in lieu of the name and address for the Manufacturer (or Supplier) element?
I would like to know if customs brokers are going to be able to use the Automated Broker Interface (ABI) system to do the Importer Security Filing (ISF).
Clarification is needed regarding which changes or errors, if any, other than a previously unreported container, would warrant a stow plan amendment, and when or how frequently they would need to be filed. It is understood that if a carrier found a stow plan error reflecting on the presence of a previously unreported container onboard, an immediate amendment would be needed.
Are we able to submit stow plans by email in Microsoft Excel format?
Are RoRo vessels exempt from the requirement to provide a vessel stow plan?
Are vessels exclusively carrying bulk and break-bulk cargo exempt from the requirement to provide a vessel stow plan?
How must ISF information be submitted to CBP?
Does an ISF Importer need to submit vessel stow plans or container status messages?
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