Universal Importer Profile (UIP)

Transcription

1 Universal Importer Profile (UIP) A platform for a Streamlined ISF Appendix A Docket Number USCBP National Association of Manufacturers

2 Universal Importer Profile (UIP) What is it? A platform to enable importers to submit streamlined ISFs to CBP Optional- an importer can file traditional ISFs if it prefers An importer profile that includes the universe of a company s suppliers, product HTSUS #, countries of origins, manufacturers, and other data elements. The importer would update the profile on a regular basis to keep it current. How does it work? 24 hours prior to lading, the importer would submit a streamlined ISF containing two data elements: 1) the bill of lading number and 2) its profile number to CBP. This would allow CBP to screen and run its algorithms against individual shipments prior to lading to identify any risks. If the importer deviated from the data contained in the profile, the importer would file a traditional ISF as currently required 24 hours prior to lading. Importers have the option to maintain the UIP or to submit traditional ISFs linking the data elements.

3 Universal Importer Profile (UIP)- Industry recognizes that any change to the current form of 10+2 must: Address risk Provide data to CBP 24 hours prior to lading Provide shipment specific data Why is the UIP needed? Complying with the 10+2 rule is extremely burdensome, costly and difficult The current rule creates significant supply chain delays that increase costs and create new security threats A new approach is needed to meet the needs of CBP without unduly burdening trade

4 Universal Importer Profile (UIP)- How does the UIP address CBP s security concerns? The UIP allows CBP to target specific shipments prior to lading The UIP provides CBP with significantly more opportunity to identify high risk transactions within any given supply chain more so than the original 10+2 CBP can still issue DNLs against an UIP shipment The UIP increases supply chain transparency The UIP addresses the security threats raised in the two examples continually used by CBP (e.g., the casings and transshipment examples) How will the UIP impact CBP and industry? The UIP will improve security without unduly burdening trade The UIP will reduce supply chain delays The UIP can be used for other import initiatives as well and streamline customs operations For both CBP and Industry the UIP requires more up front work CBP will have to develop algorithms to target all permutations within a supply chain Industry will have to create robust profiles containing detailed information on their supply chains

5 Universal Importer Profile (UIP)- What the UIP isn t: A profile that grants access to third parties. ONLY the importer and CBP have access to the UIP Mandatory: a company may choose not to use the UIP

6 The UIP in detail Requirements to use the UIP Importer submits an application to CBP to create an UIP (i.e., similar to the FAST process; C-TPAT validation could be used as a/the factor; CBP can designate criteria such as trusted shipper status) The importer would construct an ISF data summary table that identifies all possible values for each of the ten data elements in its ocean freight supply chain, and upload it to a secure, web-based portal, such as ACE, the C-TPAT portal, or other portal managed by CBP The importer would be responsible for putting into place procedures to ensure the ongoing maintenance of their profile for accuracy, completeness, and timeliness, such that all new data is uploaded to the portal at least 24 hours in advance of lading cargo on the first shipment that incorporates the new data value Using the UIP to comply with the SAFE PORT Act of 2006 mandate: CBP assigns each importer an UIP number either by company or individual importer of record numbers The importers would file a streamlined ISF for each shipment with CBP 24 hours prior to lading The streamlined ISF would require two data elements: the UIP# and bill of lading number 24 hours prior to lading this allows CBP to target each shipment If a shipment is outside of the UIP, the importer is required to file a traditional ISF containing the ten data elements

7 SAMPLE UIP for 10+2

8 How Does UIP Accomplish CBP s Targeting Goals? The UIP allows CBP to target each specific shipment prior to lading while allocating greater resources to traditional ISFs and high-risk transactions For importers with UIPs, CBP can target individual shipments prior to lading by running algorithms against the UIP to detect any permutations that raise red flags National Targeting Center resources will have greater capacity to analyze traditional ISFs once streamlined ISFs have been analyzed and deemed low-risk. Importers who have UIPs will be able to provide a more comprehensive listing of the 10 data elements. More comprehensive information will enhance Customs targeting efforts and provide Customs with the ability to build a more detailed importer profile CBP can issue do not loads against simplified ISFs if a problem is identified just as it can against traditional ISFs The UIP increases supply chain transparency and provides CBP with significantly more opportunity to identify high-risk transactions within any given supply chain When the importer utilizes the UIP, CBP can apply its targeting technology well in advance of the 24 hours As soon as CBP has received information on potential threats, it can run it against the profiles to identify risks. This can occur without a specific shipment The additional time will afford CBP the opportunity to work in partnership with the importer to further assess and mitigate high risk variables Corrective actions can be taken in advance of an order being placed on the supply chain, let alone vessel lading Improved accuracy of cargo descriptions Streamlined ISF filers are responsible for uploading accurate, complete, and timely data into the portal once, and as updates are necessary, affording CBP an opportunity to carefully scrutinize the inputs; traditional ISF filers will be prone to clerical errors that could inadvertently flag high-risk shipments as low-risk, and vice-versa UIPs will contain all possible values for an importer s ocean supply chain movements; whereas values submitted on a traditional ISF are often subject to change once the vessel leaves the foreign port as a normal result of legitimate international trade practices. The UIP would prevent the two scenarios CBP has used to explain the need for advanced cargo data (e.g., casings and transshipment) The UIP meets the SAFE PORT Act of 2006 Congressional mandate Importers provide advanced data to CBP 24 hours prior to lading CBP is able to target high-risk transactions Facilitation of lawful trade The UIP would not create risky or costly supply chain delays thereby facilitating trade while allowing CBP to target individual transactions

9 Traditional ISF vs. Streamlined ISF Security Need Traditional ISF Streamlined ISF Target Specific Shipments Yes Yes Identify potential risks prior to the filing of an ISF? No Issue DNLs prior to lading* Maybe Yes Provide a more detailed description of the shipment? Allow for penalties for non-compliant importers Yes Yes Require filing 24 hours prior to lading Yes Yes Meet the Legislative Mandate? Yes Yes Creates significant supply delays? Yes No Creates new security risks?** Yes No Yes Yes Yes The streamlined ISF actually provides greater security benefits than the traditional ISF *Depending on when lading occurs, under the traditional ISF the DNL may not be issued until after the container has been loaded which could create significant disruptions to port operations ** Freight at rest is freight at risk. Under the traditional ISF, fully loaded containers will sit idle while importers process and submit the ISF.

10 UIP and Trusted Partners The UIP is an optional program. Some importers might choose to submit all streamlined ISFs, while some might prefer to submit all long ISFs. Other importers might find a combination of the two methods to be most effective for their operations. Trusted importers can take advantage of the relationships they already have with their assigned Supply Chain Security Specialists to understand whether adjustments can be made to improve supply chain security, and they can upload their ISF data summary tables to their existing C-TPAT secure web portal accounts. The compatibility of the UIP with the C-TPAT program has great potential to advance the customs-trade partnership to a whole new level of supply chain security excellence, while raising the incentive for importers to invest in the program.

11 UIP and Precedent The UIP helps advance CBP and Congress goal to create a single window for customs operations There is precedent that supports implementation of the UIP for the ISF The FAST program verifies trade compliance and security concerns away from border while facilitating the movement of pre-approved eligible goods across the border quickly FAST is aligned with the trusted importer concept The FAST program relies on risk management principles, supply chain security, industry partnership, and advanced technology to improve the efficiency of screening at the land borders FAST participants are required to submit an application, agreement and security profile to CBP The FAST program allows CBP to redirect security efforts and inspections to high risk transactions CBP already operates the MED-PID database for FAST that could be used as a foundation or model for the UIP

12 UIP and the Future International Harmonization Could work with the WCO s Unique Consignment Reference (UCR) to facilitate international data models Utility for other customs operations including USDA, FCC, FDA requirements, etc The UIP is a more efficient use of limited government resources