WEBINAR: 10+2: Finding a Way Forward

Transcription

1 WEBINAR: 10+2: Finding a Way Frward Fllw up t webinar questins ACE At sme pint will the ISF data be available n ACE? The ISF data is nt available in ACE at this time. It will be quite sme time until ACE includes ISF data accrding t Lu Samenfink f CBP. AMENDMENTS Can yu help us ut with the timing f making amendments and by when must filers submit the updated data? CBP has nt specified hw quickly the amendments must be made ther than stating that amendments shuld be filed when the changed r mre accurate data becmes available. The Imprter Security Filing must be amended if there is a change r mre accurate infrmatin becmes available befre the gds enter the limits f a prt in the United States. Fr gds that will be unladen in the United States, the Imprter Security Filing must be updated if there is a change befre the gds enter the prt f discharge. Amend ISF fr quantity? Why? Beth misspke, quantity is nt required fr ISF s. AMS Are yu filing yur ISF prir t AMS filing? Fr vessel carriers, that are nt bulk r apprved break-bulk, CBP must receive frm the carrier the carg declaratin infrmatin in AMS 24 hurs prir t the lading f carg n the vessels, and fr autmated NVOCCs, the carg declaratin infrmatin merely needs t be transmitted 24-hurs prir t lading f carg. ISF is als required 24 hurs prir t lading f the carg but we re anticipating that carriers will require the infrmatin even earlier. BILLS OF LADING When Custms implemented 10+2, I dn't recall anyne mentining that a Huse r Master Bill f Lading wuld be needed t track the shipments. I'm assuming this is needed s Custms can tie the infrmatin tgether. Why wasn't mre emphasis placed n this? This really isn't 10+2, it shuld be called Is this infrmatin necessary? Yu are crrect that the bill f lading is needed t identify the shipments and t tie the ISF filing t the carrier status messages and stw plan. In additin t the bill f lading, yu are als required t submit a filer cde and a bnd type s its really 13-2.

2 What ties the imprter's 10 data elements t the carrier's 2 data elements? The lwest level Huse r Master bill f lading. Can yu recmmend the best way t crdinate r time the filing with the bill f lading submissin frm the carrier? I m hearing that imprters are finding it difficult t get their BOL frm their cean carrier early enugh s they can file the ISF in a timely fashin. Hw are the carriers respnding t this situatin? We re hearing this t. Accrding t CBP The ISF Imprter must btain the bill f lading number. The bill f lading number is an integral part f the security filing. Withut the bill f lading number, the ISF cannt be matched t a custms manifest. Yu are ging t have t wrk with yur carriers t get these numbers up frnt. Yu cannt use a dummy number and then replace it with the crrect bill f lading number because the bill f lading number is the ISF identifier. Yu wuld have t submit a new ISF if yu have a different number and this wuld prbably be cnsidered a late filing. We are seeing that carriers are using bking numbers t cnvert t Bill f Lading numbers t make them available. This shuld becme a standard. (Thank yu audience member fr this infrmatin). We have heard similar prcess changes arund using the bking number (plus carrier SCAC) as the bill f lading numbers. Imprters wuld have t verify this prcess with their respective carriers. Sme rigin 3PL s are als cnsidering prcess changes arund the timing fr submitting shipping instructins (BL Instructins). 3PL s are cnsidering hlding-ff n submitting BL instructins until an ISF has been submitted/apprved i.e. ptential fr mre delay at rigin as Je mentined during the webinar. At what event is the B/L number created by the carrier? It varies by carrier. Yu shuld wrk clsely with yur carrier t ensure that they are assigning the bill f lading number early enugh fr yu t file the ISF 24 hurs in advance f lading the gds n bard the vessel at the freign prt f lading. Currently we were given advice t put "any number" in the Bill f Lading Number field that des nt exceed 10 digits f curse. When we receive ur BL # then we can issue an amendment. 1) Are they capturing this issue in the 15% failure rate, and 2) D yu see this shwing up n the reprt card, 3) This wuld clearly be a vilatin after 1/26/10? Finally, hw are the carriers ding n cmpliance? Yu cannt amend the bill f lading number n and ISF. Yu will be required t cancel the ISF with the incrrect number and resubmit. Hwever yu risk filing yur ISF late in this case. We d nt believe that incrrect bill f lading numbers are resulting in ISF failures. The reprt card includes a Frequency f ISF-10 Filings by Number f Days Leading/Lagging Bill Filing Date but it s nt clear what this is actually measuring.

3 Can yu use yur bking number as yur BOL number fr ISF? Yes, if the bking number is the same as the bill f lading number. I'm cnfused abut filing multiple b/l's per ISF. Des this mean I can have multiple parties per ISF. Example if I have ne b/l can I have multiple sellers and buyers. If I have multiple b/l's can I have multiple buyers and sellers als? A single ISF may cver multiple bills f lading as lng as they are all ging t the same imprter as part f the same shipment n the same vessel vyage. Fr an imprter that uses NVOs, is B/L cncern the Huse r Master B/L? It s the lwest level bill f lading available. BONDS Des the shipper need a bnd if their brker is filing as their Designated ISF10 filer? CBP is pstpning the requirement fr bnds until January 26, At that time, the ISF filer may use the imprter s cntinuus bnd r their agent s bnd. It s imprtant t determine wh s bnd will be bligated as part f yur Standard Operating Prcedures and if yu d utilize yur agent s bnd, yu will want t understand the csts t d s. Is there an additinal bnd required t what is already in place? Nt at this time. It isn t very clear hw CBP intends t implement the bnd requirements and yu shuld stay in tuch with yur surety cmpany while this is being further defined. Is a separate bnd required t file the ISF? N, CBP is pstpning the requirement fr bnds until January 26, At that time, the ISF filer may use the imprter s cntinuus bnd r their agent s bnd. BULK What if I ship bulk and my shipment ends up in a cntainer with ther shippers...if they are delayed due t ISF issues...will that delay my shipment t? Yu are required t submit an ISF if yur bulk gds are placed in a cntainer. If yur cntainer includes ther LCL imprters, yur gds culd be held up due t items being imprted by ther parties included in the cntainer that yur gds are shipping in. Is this statement crrect fr break bulk? If the carrier yu are using had applied fr and received a break bulk exemptin frm the timing requirement fr carg declaratin under 19CFR 4.7(b)(4)(ii), fr ISF yu can get an exemptin frm the 24 hur rule befre lading and yu can file the ISF 24 hrs befre arrival in the USA. If the carrier des nt already have the exemptin in place yu must file 24 hurs befre the vessel is laded at the pint f exprt.

4 Yes, break bulk has a timing exceptin yu can file yur ISF fr break bulk 24 hurs in advance f arrival f the merchandise. BUYER Fr the "first sale" rule, des CBP want t see the "first sale" buyer (middle man) r the end buyer (cnsignee)? It wuld be the buyer at the time f the ISF filing. If the buyer changes during the sailing, an ISF amendment will need t be filed. CARRIER STATUS MESSAGES Are status messages being sent fr all ISF filings? Carrier status messages are required t be filed fr every ISF. The carriers are subject t penalties if they fail t file status messages. CBP Representative Hw d we cntact a CBP rep in ur specific New Yrk area? We recmmend that yu start with yur (r yur brker s) ABI/AMS representative, they have all be trained. Als, CBP has utreach events scheduled fr March in New Yrk. CONFIRMATION Where and hw will the rigin knw that the ISF filing has been dne in the USA n time and has been accepted? CBP will transmit an acknwledgement t the filer t cnfirm that CBP has received an Imprter Security Filing. The ISF filer will have t frward that cnfirmatin n t rigin. Have yu heard f the very recent issues with CBP and their system nt returning cnfirmatin numbers N yu shuld be receiving cnfirmatin numbers. Have yu heard regarding the fllwing; 1. CBP cntinues t have spradic difficulty with the ISF prgram, whereby CBP fails t return the ISF Number t the filer. 2. CBP has n prvisin t resend an ISF number t the filer under nrmal circumstances. 3. FOR THE MOMENT - if the filer receives a "Duplicate ISF" respnse message frm CBP (DUPLICATE ISF TRANSACTION), the filer is t cnsider that message prf f ISF filing. 4. CBP is reviewing the ISF prgramming and is cnsidering methds t return an ISF number back t the filer when a duplicate ISF is filed. 1. N, but we ll ask American Shipper t fllw up n this. 2. Yes, CBP will nly send an ISF cnfirmatin and des nt resend it.

5 CONSOLIDATOR 3. N, we d be cncerned with this because the imprter desn t have any visibility t what was filed s they have n way f knwing that it was filed in a timely, cmplete and accurate manner. 4. Great that wuld be very helpful. On FCL shipment being stuffed at factry, wuld freight frwarder, wh arranged the shipment, be listed n the ISF under CONSOLIDATOR r wuld the factry, where gds being stuffed, be listed n ISF as cnslidatr? CBP has stated that the cnslidatr (stuffer) is the party wh stuffed the cntainer r arranged fr the stuffing f the cntainer. Frm yur descriptin, it sunds like the factry is actually stuffing the cntainer and shuld be listed n the ISF as the cnslidatr. Hw can US Custms knw the accuracy f the cnslidatr name and address is crrect, this infrmatin is nt transmitted within AMS r Custms entry? CBP has nt advised hw they will be validating the names and address f the parties n the ISF. CONTRACTS What type f cntractual changes are yu hearing between buyer/seller, if any, regarding 10+2 requirements? We re seeing new terms and cnditins between the ISF filer and their agent. We re seeing lead time requirements. We re seeing (sme) pricing agreement fr ISF filings and amendments. COST Where did yu get this $20-50 price range? We are NOT seeing this in the market and we're and ISF filer This is frm sftware vendrs wh are prviding the sftware t imprters wh will be self filers. Are mst brkers charging a flat fee fr dealing with ISF r d yu get the sense that the brkers are lking t charge fr every time they g t yur imprt file and input data n a rlling basis? We ve seen brkers charging an ISF set up fee, an ISF filing fee and an amendment fee. We re seeing charges fr everything related t ISF filings. Yur ISF filer is likely t charge yu fr each filing. Yes. COUNTRY OF ORIGIN

6 Is cuntry f rigin ne f the filing requirements that can be amended if there is a difference? All f the data elements can and shuld be amended if there is a difference. And yes, the cuntry f rigin is ne f the fur data elements that CBP will have flexible interpretatin f in additin t the Manufacturer (supplier) name/address, Ship t party and the Cmmdity HTS 6 digit. CUSTOMS BUSINESS We are a lgistics management cmpany with cntinuus bnds in place. We use custms brkers t handle ur imprts. What des "nt custms business" mean? Why is Custms requiring the data if the data is nt Custms business? We can t answer fr CBP, but we re happy t make assumptins. Because the ISF requirements seriusly exceed what has been cnsidered Custms business until nw, we believe that they have specifically stated that the ISF is security related rather than Custms business t avid legal challenges. CBP is requiring the data fr the purpses f T help prevent terrrist weapns frm being transprted t the United States. On the questin f "Custms Business", dnt yu think that is r will be "Custms Business" given the cnsiderable verlap between the data required n a 3461 / 7501 and the ISF? This is a slippery slpe and we think that CBP will try t avid ging dwn it. DO NOT LOAD If smething is wrng with a ISF, will CBP issue "D Nt Lad" frm prt f lading? The interim final rule did nt state that CBP will issue a D Nt Lad message fr ISF filings. Hwever, CBP has stated that the D Nt Lad message is ne f many enfrcement tls that they will utilize fr shipments that pse a security risk. FLEXIBILE INTERPRETATION If imprters are under previus requirements t exercise reasnable care fr their custms cmpliance, then shuldn t the imprter knw its vendrs and prducts and be able t prvide the inf right away? The ISF is nt cnsidered custms business s the reasnable care requirement des nt apply. What level f detail is required, meaning if the 7501 will have 20 HTS#s, all within the same chapter, fr duty cllectin is this level required fr ISF? Is this basically a pre-imprtatin entry and will ISF data be cmpared with the duty paid entry? If the 7501 wuld have 20 HTS numbers, yu are required t file 20 HTS numbers at the 6 digit level in yur ISF. If yu file a Unified Entry, yu can assume that the ISF data will be cmpared t the duty paid entry. But please nte, CBP has expressed that they will be flexible in the interpretatin f the data received in the ISF. If yu d nt have visibility t the 20 HTS numbers until the gds have been discharged at the U.S. prt f arrival,

7 yu have a gd case fr CBP being flexible and accepting the HTS numbers that yu can prvide. Yu shuld discuss this with yur CBP Accunt Manager. FUTURE Where will we be five years frm nw? Will cmpliance cme relatively smthly as it did w/24- hur rule, r since this is much mre cmplex, will the cst and impact be greater? This is a much mre cmplex request and is very different frm the 24 hur rule. The infrmatin required fr the ISF is usually spread acrss multiple supply chain participants and requires aggregatin and validatin. It s anticipated that ISF cmpliance will be much mre difficult. CBP is lking fr cmments frm the trade by June 1 cmmunicating the cmplexity and cst t cllect and file their ISFs. HTS D yu use yur vendr s HTS r yur HTS? Yu are required t submit an accurate HTS number at the 6 th digit level unless yu are filing a unified filing. If yu are filing a unified filing, then yu are required t submit a 10 digit HTS. It s recmmended that yu submit yur HTS, this assumes that yu fllwed reasnable care in assigning the classificatin. Is the HTS number prvided by the supplier in the ISF expected t match the classificatin f the CHB The HTS number submitted in the ISF shuld match the HTS number n the entry. IN-BOND Fr In-Transit Carg - yu mentined 2 parties can submit ISF5. Either: Filler - Carrier Can NVOCC filling AMS fr these submit ISF5? Fr Transit Carg the ISF filer is required t file 5 data elements and the ISF filer culd be: The 7512 filier fr Immediate Exprtatin (IE), Transprtatin and Exprtatin (TE). Or the carrier/nvocc fr Freign Carg Remaining On Bard (FROB). Des the regulatin apply t Canadian bund carg transiting U.S. prts Yes, an ISF-5 is required fr carg transiting U.S. prts. There are requirements fr temprary imprts 5+2 Yes, these are the ISF-5. INTERIM FINAL RULE

8 I'm hesitant t invest time and mney in enhancing r mdifying ur existing systems t submit the ISF nw with the fact that a prtin f this new law is nt final (interim). Is this a cncern? The nly cmpnents f the rule that are nt final are the timing f the filing f the Cntainer stuffing lcatin and the Cnslidatr name/address; the flexibility f interpretatin f the Manufacturer (supplier) name/address, Ship t party, Cuntry f rigin and the Cmmdity HTS 6 digit; and enfrcement by CBP. We think it is definitely a cncern. But we als expect that CBP will cntinue t define and update the transactin sets. ISF DATA What pieces f infrmatin are typically mst difficult t get by the imprters (frm utside their walls)? It depends n the cmpany, their supply chain mdel and their industry. We ve heard f cmpanies having issues with mst f the data elements. ISF FILINGS I'm a nvice, what des actually refer t? Dcuments? The ISF is an electrnic filing with CBP required 24 hurs prir t lading the gds n bard a vessel at the freign prt f lading. The interim final ruling n ISF can be fund at Hw wuld a shipper knw if a freight frwarder r brker ther than the ne the shipper has designated t file as their ISF10 filer has filed first with custms fr the shipper? If anther party has filed an ISF n yur behalf, yu wuld receive a rejectin when yur designated agent attempts t file. That s the nly way that yu wuld knw that smene else has filed yur ISF. Wh is respnsible fr ensuring the SF has been filed prir t a cntainer being laded n a vessel? The imprter? The carrier r shipper? The ISF filer is respnsible fr ensuring that the ISF is filed in a timely, cmplete and accurate manner. If it is nt, the ISF filer will be subject t liquidated damages f up t $5,000 per ISF effective January 26, We are a wine imprter and sell ur wines with FOB terms t distributrs acrss many states. In this scenari, wh is respnsible fr the ISF filing? Us r the distributr wh is buying FOB? Thank yu. The wine industry is particularly challenging because f this type f business mdel. Technically, the persn causing the imprtatin t ccur wuld be the ISF filer. Our understanding is that yu dn t knw wh the distributr is when the gds are laden n bard s yu wuld be respnsible fr filing the ISF. This culd be an issue because yu will incur risk f ptential liquidated damages as the ISF filer.

9 Des GT Nexus have a 10+2 sftware slutin? Standalne r as part f package? Yes, GT Nexus has a 10+2 slutin delivered as Sftware as a Service. Are there any preliminary statistics n hw many cmpanies are pting t self-file fr ISF? N, but that s an excellent questin fr a security survey. Can yu have mre than ne fwarder file the ISF fr yu? Yes yu can nminate as many ISF agents as yu want. And yu can utilize a mixture f self-filings and filings via agents. Hw des 10+2 apply t U.S. gvernment shipments? Exactly the same as cmmercial shipments. Pint f clarificatin. Filing must be dne 24 hurs OR MORE prir t lading, right? There is n maximum timing is there? Crrect, yu can file yur ISF as far in advance as yu want t. Is their an free internet based way t file these yurself (like the AES) N. As an NVOCC wh des nt cnslidate (nly handle FCL), and typically nly handle exprts frm the US we are beginning t imprt and I wanted t knw are we respnsible fr the 10+2 filing r is the actual imprter f recrd? - Thank yu. The party causing the imprt t ccur is respnsible fr the ISF filing. Is there any hpe that 10+2 will g away? Only if the trade prvides a very cmpelling argument as part f their cmment filed by June 1, 2009 in respnse t the Interim Final Rule. Will Snw Days by custms be declared n ISF issues?? CBP has nt addressed this at all. Snw Days are a U.S. issue and the ISF filing is required at lading s the assumptin wuld be that they will nt be cnsidered. As this is an alternative t 100% scanning, shuldn't we quit cmplaining s much? That s the lgic. The trade realized that imprving security is critical and we had hped that the ISF wuld be a reasnable alternative t 100% scanning. Unfrtunately, CBP did nt take all f the trade s recmmendatins int cnsideratin when they issued the Interim Final Rule. What abut shipments that riginate in a freign prt and then transladed in the Bahamas nt anther cntainer/b/l des anther ISF need t be filed?

10 The ISF filing wuld be frm the prt f translad in this case. What are the requirements f a 10+2? My brker asks fr cpy f B/L, cmmercial invice, and packing list alng with the 10+2 tgether? Or can the 10+2 just be sent first as lng as the 10 fields are filled then the ther dcuments be submitted later? The bill f lading, cmmercial invice and packing list are required fr the entry filing. Yu shuld be able t prvide this t yur brker anytime befre the gds can be prefiled fr entry which is five days in advance f arrival. That said, these dcuments d cntain infrmatin that can be used fr the ISF filing. Its up t yu if yu want yur brker t extract the data frm yur dcuments r if yu want t prvide them with the 10 (really 11 data elements) separately. MANUFACTURER: What if it is a triangle business and shipper refused t prvide the manufacturer infrmatin t imprter then hw can we file the ISF withut the accurate manufacturer infrmatin? It is perfectly acceptable t substitute the supplier name and address if yu d nt knw the manufacturer name and address. If using an agent verseas, d we have t find the actual manufacturer especially n parts shipments N, yu can substitute the supplier name and address if yu d nt knw the manufacturer name and address. MESSAGING What happens if yu get a message frm CBP saying there are n match with BOL and if thse messages cntinue up t 30 days? These messages are being prvided at the request f the trade. CBP will prvide a status ntificatin message t bth the ISF Filer as well as the apprpriate carrier that an ISF has successfully matched t a bill f lading that is n file with CBP. If there isn t a match yu ll get these messages fr up t 30 days. As the ISF filer yu are nt required t ensure that the ISF is matched t the carrier s status message r stw plans. MODES Will 10+2 be expanded t air and land in the near future? CBP plans t expand the ISF t ther mdes f transprtatin nce they have successfully implemented ISF filings fr cean shipment. Can yu tuch n the truck and rail cmment made early n? Yes, currently the ISF is nt required fr gds arriving in the U.S. via truck r rail. This includes gds arriving in Canada r Mexic via cean that are mved int the U.S. via truck r rail.

11 NON-US D we knw which ther cuntries already have r may be cntemplating future "10+2" imprt prcedures? If s, culd there be prgressively an internatinal "standard" fr 10+2 type imprt prcedures, whether glbally r reginally (NAFTA, UE, Asia)? Canada and China bth have similar prgrams at varius stages f implementatin. Any thughts n hw fits with the EU AEO prgram r discussins befre the WCO t standardize the effrt? Nt at this pint. T date the WCO has been very vcal in their bjectin t the ISF requirements. Hw clse is Canada t requiring ISF? Canada has published infrmatin n the Imprter Admissibility Data but it des nt include a timeline. Canadian Custms just intrduced its plan t implement 10+2 under its new e-manifest fr air, land and maritime. Are there any bi-lateral effrts t impse the Canadian and US versins in the same fashin at the same time? Nt at this time. Puert Ric? Puert Ric is a territry f the U.S. and is cnsidered within the scpe f this Interim Final Rule. PENALTIES Any cmments n frwarder/brker liability if their sftware prmpts an errr causing liquidated damages? In mst cases (brker errr r sftware errrs) the imprter receives the penalty ntice. In the case f the ISF, the assumptin is that the bnd hlder will receive the penalty ntice. But this can t be verified until CBP prvides mre detail n the bnd requirements. What is the likelihd f stringent enfrcement f 10+2? I ask that because f the cncerns back with the 24-hur rule. And CBP was less stringent n that filing requirement s as t nt interfere with the flw f trade. CBP has repeatedly stated that their enfrcement f the ISF will be flexible and if they determine that mre time is needed t implement the ISF that they will pstpne enfrcement past January 26, On what unit will the $5000 liquidated damages assessed? Per b/l, per cntainer, per package?

12 CBP has stated that the $5,000 penalty is per ISF. PRESENTATION I am nt able t dwnlad the presentatin can yu prvide a link? Yu can g t and watch the recrding n-demand. REMOTE LOCATION FILING Hw has the ISF rule impacted brkers that use Remte Lcatin Filing and hw d they adapt? Per CBP yu cannt file a Unified Entry fr Remte Lcatin Filing entries. There are n ther differences between a standard entry and an RLF entry. REPORTING Culd CBP prvide a list f all the issues s far reprted and expected fix delivery? CBP has stated that they will prvide an ISF reprt card. Issues that we see with the reprt card are that they dn t state hw many ISF s yu shuld have filed. Or hw many amendments yu have filed. It is unclear frm the sample reprt card whether there is sufficient detail fr yu t research issues fr example if yu have a 50 percent cmpliance fr manufacturer name hw d yu find ut which shipments these errrs are stemming frm? CBP is ging t have data that shws nn-cmpliance but yu wn t be able t address the rt cause f the issue if yu dn t have enugh detail. We have als asked CBP t prvide American Shipper with data n hw many ISFs shuld be filed versus hw many are being filed. When will CBP begin sending ut ISF "scre cards" t imprters and brkers? We dn t knw. We understand that the reprt cards will be sent t the ISF filers but CBP has nt tld us when r hw ften. RETURN MERCHANDISE Are there different rules fr cmpanies setup utside the U.S. that ship prducts in then back? Maybe ship in parts, assemble them and ship the finished prduct back? r des this matter? The same rules apply t ISF filings fr cmpanies setup utside f the U.S. shipping prducts int the U.S. and then back. SELF FILING Can I file my wn ISF? D I need a brker r frwarder? Abslutely. Hw wuld a self filer in the US file the ISF at rigin??

13 Thrugh an ABI/AMS vendr r in-huse sftware that is designed fr access abrad. Hw can ne file themselves when using a custms brker t handle the imprt entry? By using 3 rd party sftware, such at GT Nexus slutin. What are the prcedures fr self filing? The filer needs a filer identificatin cde. Either a SCAC if transmitting thrugh AMS r an ABI filer cde if filing thrugh ABI. And the filer needs a system t file with. This culd be develped in huse r a 3 rd party sftware slutin. SHIP TO PARTY Please cnfirm either Imprter ID r Dun & Bradstreet number, in additin t name and address, is required fr bth the Ship t party and the Buying Party. The Imprter ID is required fr the Imprter f Recrd. A Dun & Bradstreet number can be used fr the Seller, Buyer, Manufacturer (r supplier), Ship t party, Cntainer stuffing lcatin, Cnslidatr (stuffer), and Bking party. In additin, CBP will accept Facilities Infrmatin and Resurces Management System (FIRMS) cdes fr the ship t party, when applicable. UNIFIED FILING Can CBP accept unified entries fr ISF? Our brker says they can't d it yet, but I wanted t cnfirm CBP can accept and sme parties are ding this. Yes. This is an issue with yur brker. There are many brkers wh are currently filing Unified Entries. Current regulatins allw fr entry filing 5 days prir t arrival. Hw is this impacted if the ISF is cmbined with entry? Yu will file the Unified Entry at least 24 hurs in advance f lading f the merchandise n bard the vessel at the freign prt f lading and yur entry will nt be prcessed until five days in advance f the arrival date. CBP has suggested that they may cnsider changing this, but haven t enacted any changes yet. As an imprter Je, which wuld yu d, stand alne r unified Je sees value in filing Unified Entries. Beth is cncerned with the risk f the Unified Entry being used fr cmpliance measurement. Is the ISF data cmpared t the data f the final declaratin? And is there a reprt available as well? Yes, fr the Unified Filing. Prbably fr the separate filing. There is n reprt that cmpares the ISF filing t the entry filing at this time.

14 CONTACTS: Je Burks Cper Wiring Devices Inc Eric Kulisch American Shipper (202) Beth Petersn BPE Sunil Sharma GT Nexus