Importer Security Filing (10 + 2 Rule)

On January 26, 2009, the final rule regarding submission of the Importer Security Filing (ISF, 10 + 2) came into effect. This filing, which must be completed no less than twenty-four (24) hours prior to the loading of cargo on board a vessel at a foreign port, consists of ten data elements provided by the importer and two data elements provided by the carrier.

Customs and Border Protection have indicated that they will not begin enforced compliance for one year (until January 26, 2010). However, they have stated that importers and their agents must make a good faith effort to provide as much data as possible as soon as possible to assist in their targeting efforts. CBP will also issue progress reports and report cards to filers and importers detailing how they are doing as the filing period moves along and will undoubtedly pay far more attention to those companies who require corrective action or persistent attention.

This is really the second stage to the AMS filing requirement which is often called the twenty-four hour rule. While the AMS data is manifest level data (think the contents of a bill of lading), it does not get to the actual movement of the cargo through specific parties in the supply chain. CBP is seeking that information based on some of the data elements which are required, such as the names and addresses of manufacturers, container stuffing locations and cargo consolidators. This data, which is considered a security filing, will NOT be shared as manifest data is right now through any of several reporting and publishing agencies.

In our December, 2008, News Alert, we included a document by a leading Customs attorney which gave a good high-level primer about the data elements and the program requirements. It can be found here.

The Camelot Company has done its best to notify our existing clients and partners of their responsibilities for the new filing. In addition, Customs published and made available an FAQ which will be periodically updated on their website. For importers or agents seeking documents which Camelot has generated about this new filing, we would ask that you please review the documents under the appropriate heading.

Importers:

ISF Importer Security Filing Submission Form
ISF Letter to Clients
ISF Letter for Clients for Suppliers
ISF Election Form

Agents:

ISF Letter to Agents
ISF Agent Notification Receipt and Acknowledgement