SCDigest Editorial Staff
| Ahern Says: |
 I’m not interested in any pilot that’s going to delay implementation." Ahern said, Importers are going to have to “focus on reality” and realize they are going to have to comply with the rule.
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The long discussed “10+2 rule” – a pair of new security filings that must be made by importers to the US Customs and Border Protection (CBP) agency, is on the verge of implementation.
Requirement for the filings ““a matter of days or weeks” away,” Deputy Commissioner Jayson Ahern told the Journal of Commerce yesterday.
The new regulations ultimately stem from The Safe Port Act of 2006, but it was not until early in 2008 that CBP issued its draft requirements. Officially called the Import Security Filing, the proposed rules became known as “10+2” because they require two electronic filings for imported goods – one consisting of ten data elements, and then two additional ones as the goods move closer to the inbound port.
The ruling requires Importers or their designated agents to file “10” types of data elements 24 hours prior to vessel lading overseas (see table below). The vessel operator will have to submit the other “2” data elements 48 hours from the vessel departure from the foreign port.
Data Element |
Brief Description |
Challenges |
Manufacturer Name and Address |
The entity that last manufactures, assembles, produces or grows the commodity |
One of the most difficult data to gather; often, actual manufacturers and actual address will not be known; supplier may not want to divulge details, or have bad data |
Seller Name and Address |
Last known entity by which the goods are sold or agreed to be sold. If not sold the owner is reported |
Typically known through the commercial invoice and/or purchase order issued by the Importer |
Buyer Name and address |
Last known entity to which the goods are sold or agreed to be sold |
Typically known through the commercial invoice and/or purchase order issued by the Importer |
Ship To Name and Address |
The first deliver to party scheduled to physically receive the goods after release from Customs |
Unique to the 10+2 rules |
Container Stuffing Location |
Name and address of the physical location(s) where the goods were stuffed or if break bulk goods, where they were made shipment ready |
Data element known only at the origin, typically by the supplier or Freight Forwarder; unique to 10+2 |
Consolidator Name and Address |
The party which stuffed the container or arranged for its stuffing. For break bulk goods, again the party who makes them shipment ready |
Will have similar challenges to the container stuff location |
Importer of Record Number |
The IRS, EIN, SSN or CBP assigned number of the entity liable for payment of any duties and responsible for meeting all import requirements |
Typically known by Customs broker |
Consignee Number |
The IRS, EIN, SSN or CBP assigned number of the entity on whose account the merchandise is shipped |
Typically known by Customs broker |
Country of Origin Code |
Clarified to include the country of the manufacture, production or growth, based upon import law definitions and other rules and regulations |
Typically known by Customs broker |
Commodity HTS number |
Still require to the 6-digit level, but allowed to be reported at the 8- or 10-digit level. |
Classification often done by the broker |
Source: Kewill |
“One major change that is not evident when you review the data elements is the requirement to link certain required information," a recent white paper on the topic from Kewill recently noted. “CBP is requiring that the manufacturer name and address and country of origin be linked to each of the commodity HTSUS [Harmonized Tariff Schedule of the United States] numbers. For many suppliers, this will require a change to their commercial invoice format to make sure this data is available at the line item level.”
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