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10 + 2, Your time is up !
All Importers should be aware that for ocean shipments, Customs and Border Protection’s (CBP) stated position is that they will move from a relaxed enforcement mode to a rigorous enforcement mode of Importer Security Filing (ISF or 10 + 2) as of January 26, 2010.
CBP’s expectation is that importers, brokers, forwarders and suppliers, in short everyone involved in the supply chain that moves goods from overseas into the U.S. have used the time since inception of the ISF regulation in January of 2009, to make sure that the required information is provided to them in the correct format and within the mandated time limits.
Cavalier has implemented new procedures and updated software to allow us to send the ISF data to CBP and we have counselled both our clients and agents as to their responsibilities. We have had a great deal of success in these areas but there is still work to be done and there are still importers who have not yet understood the gravity of non-compliance.
It is important to understand that ISF is all about security and preventing the importation of shipments that may include items that would be harmful to individuals or companies. As your Customs Broker, we make ourselves aware of your products and the various agencies that regulate them to help you remain compliant. We cannot, however, guarantee the security of your supply chain, especially when we are acting only as Customs Broker and not your transport partner. We therefore need you to discuss ISF with all of your suppliers and vendors to make sure they also have your best interests in mind.
Compliance with ISF is not at all difficult as the information CBP requests is readily available from your supplier(s) and from the freight forwarder involved with the transportation. The challenge is to ensure that those parties supply the information much earlier than ever before. It is Cavalier’s recommendation that you communicate with all of your overseas vendors and let them know how critical this is. CBP has indicated that penalties for providing inaccurate and/or untimely information will be $5000.00 per error within any given ISF transmission with a maximum of $10,000.00 per ISF.
These fines will be levied on the importer.
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