CBP Security Filing on Advance Trade Data Elements (10+2 rule) sent to OMB, White House Office of Management and Budget for review.

Approval by OMB is the final step before Customs can publish the proposal in the Federal Register for public comment. The OMB’s rule summary says that importers and carriers will submit information that is “reasonably necessary to enable high-risk shipments to be identified so as to prevent smuggling and ensure cargo safety and security.” Parties will submit the data by a “CBP-approved electronic data interchange system.”

Once the proposal gets posted into the Federal Register, there will be an opportunity to submit questions and comments from the trade. Trade Bridge members are encouraged to submit those questions directly or to TBI for submission.

Trade Bridge has two pages with FAQ information about 10+2 from seminar-webinars that we have hosted with CBP staff.

October 18th, 2007 FAQ
June 7th, 2007 FAQ

CBP's official 10+2 FAQ web page has been disabled at this time for legal reasons.

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     Important Announcement for U.S. Importers 

     Free Seminar Hosted by TBI and Presenting Richard DiNucci, Director, Border Targeting and Analysis, U.S. Customs and Border Protection. 
     CBP to Speak to Small and Medium Importers about 10+2, the Advanced Data Initiative in Chicago on June 7th.

     Mike Laden, President of TBI Brokers, a Trade Bridge sponsor, met with Michael C. Mullen the Assistant Commissioner for the Office of International Affairs and Trade Relations and other CBP executives in Washington, DC on Monday, February 26th. The primary purpose of the meeting was to discuss obstacles and other barriers facing SME’s and to work with CBP on reducing the cycle time involved in becoming a direct-filer. Currently the process of getting set-up with CBP to become a direct-filer is approximately six weeks. Mike also took this opportunity to address concerns being voiced by the trade regarding CBP’s new 10+2 straw man (see article below on 10+2). It is our opinion that importer’s who opt for the direct-filing solution will be far ahead of the curve when CBP rolls out their 10+2 program (expected to be phased in as early as fall of this year). Mike also met with Mandy Bowers, Senior Staffer on the Committee for Homeland Security and with Timothy Skud, Deputy Assistant Secretary of the Treasury for Tax, Trade and Tariff Policy to advance the cause of SME’s; and to discuss the concept of direct-filing. Trade Bridge will continue an active dialogue with CBP and related government agencies in advocacy for SME’s.

     CBP’s New 10+2 Straw Man 

     Once known as ATDI (the Advanced Trade Data Initiative) this program has now been renamed 10+2 by CBP. As a part of the Safe Ports legislation CBP is now required to implement the advanced collection of 10 data elements from the importer or his agent, plus two data elements from the carrier, prior to the lading of the consignment on a vessel or other conveyance bound for the US.

     At a recent trade meeting in Houston, CBP stated that they intend to issue a Notice of Proposed Rule Making on 10+2 for public comment this spring with an end goal of a Final Rule and phased implementation in the fall. 10+2 seems to be on a fast track and CBP is currently 100% committed to the program despite recent objections from the World Customs Organization (WCO). The WCO and European Union are promoting the collection of 25 data elements in advance. This is a very fluid and dynamic process and importers are encouraged to closely monitor 10+2 developments and to voice their opinion during the rule making process. Trade Bridge has recently published WCO's Data Element Comparison Chart that compares the data element requirements of 10-2, the 24-Hour Rule, the WCO SAFE Framework and the EU Regulation; for a copy please contact Maria Catanag, Membership Sales Coordinator.
 

     Letter of Concern from Michel Danet, WCO, to CBP Commissioner Basham re: 10+2 or Security Filing

     CBP Inaugurates New Office of Trade 

     CBP has formed a new office, designed to spearhead its national trade policy, which will consolidate its trade policy, program development, and compliance measurement functions into a single Office of Trade. The Office of Trade, which will embark on its mission on October 15, 2006, will consolidate the trade policy, program development, and compliance measurement functions of CBP into one office without creating dual reporting mechanisms or overlapping, redundant management structures that would disrupt the closely interrelated activities of CBP officers and operators processing arriving cargo at U.S. ports of entry. The Office of Trade will also develop national trade policies and programs that will guide the work done by the CBP officers in ports of entry, but managing and carrying out cargo processing operations on a day-to-day basis will remain the responsibility of CBP’s Assistant Commissioner of the Office of Field Operations, working through his chain of command – the Directors of Field Operations, Port Directors and front line supervisors. For more details on the Office of Trade, click here. 

     Commissioner Basham has also announced his selection of Dan Baldwin as the Assistant Commissioner for the new Office of Trade. Mr. Baldwin, currently the Assistant Commissioner of CBP’s Office of Strategic Trade, will assume leadership of the new office upon its establishment. Mr. Baldwin brings a wealth of knowledge and experience in trade matters.