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"10+2 & The Future of Customs Compliance" Seminar and Webinar Information and Q & A


►CBP PowerPoint Presentation on Security Filing (10+2) - June 7, 2007 (PDF)

Direct-Filing and 10+2 Presentation - June 7, 2007 (PDF)
(depending on your Internet connection, this file might take a few minutes to download)

TRG Direct's Direct-Filing Auto Demo - see and hear how Direct-Filing works

WCO's Data Element Comparison - PDF download



CBP Security Filing (10+2) Q&A

  • What do the acronyms ATDI, CSI and NPRM stand for?
    ATDI stands for the Advanced Trade Data Initiative. It was launched shortly after 9/11 in an effort to capture trade data earlier. CSI stands for Container Security Initiative and is a CBP program where CBP officers are placed at foreign ports of lading. NPRM stands for Notice of Proposed Rulemaking and is a government process whereby anytime they are going to promulgate new rules they are required to circulate an official notice to Congress and all government agencies who will be impacted by the new rule. They must also allow the public at large to comment on NPRM’s, so once they are final and approved by the various departments they are printed in the Federal Register. More information on all of these topics can be found at www.cbp.gov .
  • What is the time frame to implement the "10/2?"
    CBP’s current plan is to phase in full implementation of the security filing proposal over a one year period commencing after the completion of the Federal Register Notice and public comment period.
  • Will there be another CBP meeting in another state in the USA related to 10+2...where/when?
    Yes. Dates and locations are not currently known. Check back regularly at www.TradeBridgeInternational.com or register/join at http://www.tradebridgeinternational.com/contact.aspx to receive e-mail updates.
  • HTS numbers stored in 10 digits in our system. Security requirements are for only 6 digits. Will it be possible to send 10 so we don't need 2 data sets when supplying information on imports?
    Filers may send a 10 digit HTS in lieu of the 6-digit HTS if they so choose. There is no penalty if the 6 digit option is chosen.
  • Will the same rules apply when importing from Mexico to the US from our own company in Mexico?
    Yes, the same rules will apply for imports from your own company in Mexico.
  • How will the 10 bits of info be filed with CBP? Via AMS/ABI, both? What will the electronic file look like? How will it be transmitted? For our break-bulk/bulk shipments, neither an OBL # nor a booking # is assigned to the shipment until after the shipment leaves, how does CBP plan to track the SF (security filing)?
    CBP’s current proposal is to utilize existing ABI/AMS platforms for receipt of the security filing data. However, CBP is working with its Office of Information Technology (OIT) and a number of volunteers from the trade community to explore other potential options for filing the data. Additionally, we are focused on working with OIT to ensure a seamless transition into the ACE environment.
  • How does this program align with the multilateral parallel initiatives in the works by WTO? To what extent are these initiatives coordinated to be in sync and complimentary?
    CBP is working with the WCO to ensure that the SAFE Framework and the Data Model upon which it is based are flexible and open to amendments that reflect the changing security environment. CBP appreciates the trade’s desire for uniform entry and clearance procedures in a global trade environment.
  • Does the Bonded note on the "Single Filer-Bonded" note on page 14 mean that the filer must be bonded or just the importer? When will the Test bed participants start their shipment testing process?
    A bond might be required for appointed 10+2 Security Filers. A discussion of this will be in the NPRM. Test bed shipments will not begin until the Final Rule has been issued and the waiting period has expired.
  • Currently we are importing peas and beans from Canada on truckload basis only. Our vendor there is preparing the import documents for us and charging us to do so. They are filing the 24 hour advance notice, etc. Where do we access the forms or website to file these things ourselves?
    At present 10+2 is only in concept form as it approaches the NPRM stage. Consequently there are no web sites or other tools for filing 10+2 at this time.
  • Under the Security Filing Data, I understand all the items except consignee number. Can you please tell us what the consignee number is and from whom that number can be obtained?
    The consignee number is a critical piece of information included on the entry documents submitted to CBP for clearance and entry. It is a unique identifier for the entity ultimately taking possession of the goods being imported.
  • Does this relate to customs brokers? Will this affect our system? Will it be more paperwork for us, or will there be new things we have to begin to do?
    Yes this new rule relates to customs brokers. CBP is still studying the impact that 10+2 will have on the trade.
  • Can the importer autorize their foreign carrier/NVO/forwarder to act as single filer? As most of the data elements are known overseas, this seems to make the most sense. The importer would provide the U.S. side data elements to the supplier/agent via their PO. This would ensure that shipments would not be delayed as this data filing would match 100% with the 24-hour rule filing. If the foreign VOOC or NVO files, there should be no issue with bonding as they already are required to have a C3 carrier bond. Correct? One more reason this method would make a lot of sense?
    Importers may designate an entity of their choosing to act as the filer for the security data. They may designate their broker, they may direct file, or choose other options. CBP will consider other options during the public comment period on the Notice of Proposed Rule-Making. As always, regardless of who the importer designates to file on their behalf, the importer is ultimately legally responsible for the accurate and timely submission of the required information.
  • When is the proposed changes scheduled to come in effect? The information that we are to provide is very similar to the information required under the prior notice system from the FDA. Has there been talk about consolidating this information between the two agencies?
    CBP’s current plan is to phase-in full implementation of the security filing proposal over a one year period commencing after the completion of the Federal Register Notice and public comment period. CBP, FDA and many other agencies routinely discuss opportunities to consolidate and streamline data.
  • Are the data elements already known by the freight forwarders when they file shipments or will specific elements have to be answered by the importer each time a shipment is made? If the product we bring in is the same for each shipment and come from the same source, will there be a need for the importer to provide data elements? Is there a form that the importer will fill out and submit?
    The data elements will be received from your supplier or manufacturer. At this time there are no forms that the importer will be required to complete.
  • So far, only containerized frieght has been discussed. What about material in bulk? How does the stow plan effect this, and is the manifest data still required 24 hours in advance?
    The intent is to mirror the 24-hour rule requirements regarding bulk and break bulk shipments (19CFR 4.7). This establishes, for bulk, an exemption from the requirement to submit manifest data 24 hours prior to lading, and for break bulk to apply for an exemption. Note that the bulk shipment exemption is a timing issue only as the cargo declaration must still be submitted to CBP 24 hours prior to arrival (19CFR 4.7 (b) (4)).
  • Will the 10+2 data entry of the HTS# and C/O Data detail be similar to when filing and entry at a value cutoff or will we have to go everyline detail?
    Currently concept for filing the security data will require linking the manufacturer/supplier to the HTS and the country of origin.
  • Will Free Times be changed to be more flexible than they currently are to allow for processing?
    Free time is a rule imposed by the carriers and/or terminals.
  • When requiring a single filer... is this to mean there will be no Consolidation shipping?
    No single filer does not mean there will be no consolidated shipping.
  • We have a shipper who ships to us via several manufacturers.. how will this effect shipping requirements?
    The manufacturers you use will need to ensure that the data is in the hands of your appointed 10+2 filer.
  • When do you receive the entry #?
    In today's environment the entry is typically filed just before the shipment arrives in the US or immediately after it has arrived.
  • We are a shrimp importer, subject to Anti-dumping tariff. Noticed that 10+2 for now does not apply to those imports. Any idea when?
    The process is based on electronic filing and each entry filed will require a security filing submission 24 hours prior to lading. Thus after the phased in implementation, all entries of commercial goods into the US will require 10+2, anti-dumpling shipments are not excluded.
  • On consolidated containers,how will the process work? Will Customs link information from vaious shippers or will consolidators need to submit entire container detail?
    On consolidated shipments each entity intending to file an entry is required to submit a security filing 24 hours prior to lading. There will be messaging from CBP to acknowledge receipt of the security filing so that each filer is able to inform the consolidator/ freight forwarder that they are compliant with the requirement. If one or more of the shippers in the consolidated load has not filed a security filing, the consolidator/freight forwarder can consider not placing that shipper in the load.
  • Do you foresee a fee basis similar to Harbor Maintenance Fee for the cost of this procedure?
    At this point CBP has not indicated that any fee will be due the government associated with the 10+2 filing. It is anticipated however, that unless an importer is direct-filing, that their designated agent sending the 10+2 data will charge a fee.
  • In case of a flag on container will you be doing inspection overseas or upon arrival?
    Inspections can and do occur in both places.
  • Will ACS/ACE be able to hold the 10+2 information so that data does not have to be entered repeatedly for 7501/3461 entry info or is that an issue with the filer's system for submission?
    As it is being discussed and designed now, yes, the 10+2 data set would be the beginning of the entry process with CBP.
  • Will it be possible for an importer to submit 10+2 elements by direct-file and then allow a broker to submit entry?
    As long as the importer has a system for transmitting the data to CBP, yes. At this point however, we do not envision offering a web portal for this purpose, so the 10+2 data would need to be sent via ABI or an AMS system.
  • Is this an electronic filing process? If yes, will we be given the site & training on use? Will we have clear definitions as to the 10 items that are required by the Importer? What Customs identifies as "owner" "manufacturer, etc."
    The process as it is being discussed now is electronic and will undoubtedly use existing ABI and AMS platforms. We believe that the ten data elements required by the importer are very clearly defined. The “Owner” for purposes of 10+2 filing would be the actual importer of record, or consignee of the cargo.
  • Will the current customs holds will be decreased both in frequency and time to non critical cargos?
    We do not believe that the 10+2 filing will result in more or less examinations or holds.
  • Has there been any outreach with exporters overseas? My concern is foreign suppliers send documents, return shipments, and there is an expectation for key data elements that need to be included.
    CBP is consulting with the trade community in a variety of different forums, however they do not have access to the overseas export community. CBP’s current plans for 10+2 are however being actively discussed at the World Customs Organization (WCO).
  • Will the requirements/ability change to submit entry after foreign lading instead of the current 5 days prior to arrival-15 days after arrival?
    The trade has asked that CBP allow simultaneous filing for 10+2 data and the entry/entry summary if all necessary data elements are known. CBP is currently considering this and more information will be available when the NPRM is issued.

►Direct-Filing

  • Is the TRG Direct system functional on Macintosh Computers? If so, with which web browsers? Safari? Firefox? Internet Explorer?
    Yes, TRG Direct works with Macintosh computers. The preferred browsers are Firefox and Internet Explorer but the system will work with other browsers as well.
  • When doing direct filing does the person doing the entries need a broker's license?
    Direct-filers are not required to have a customs brokers license. See http://www.trgdirect.com/RightToFile.aspx for an importer's right to file.
  • We have a facility in Canada. Is this service offered in Canada or only the US?
    TRG Direct is currently only available for imports into the U.S. However, an importer can use TRG Direct (direct-filing) into the U.S. and continue to file Canadian entries using a broker.
  • If we register under this direct filling program, can we process our own entries into the US without using the brokers help?
    Yes, using direct-filing an importer can make U.S. customs entries without the use of a customs broker. However, TRG Direct has licensed brokers on staff and can help an importer by doing assisted entries as necessary. The broker is available on an as-needed basis.
  • If you begin self-filing, and after a while would like to become a licensed broker, is that possible utilizing your system as a platform?
    Yes we have licensed brokers using the TRG Direct system.
  • Our organization currently uses brokers, freight forwarders, etc for our imported shipments. From Jan - May'07 we have imported approx 350 containers. If we have made the decision to file ourselves, no longer using a broker, what resources are available to help us get educated regarding proper paperwork, deadlines, etc.?
    TRG Direct has several levels of training available for importers starting with the FAQ on the TRG Direct web site: http://www.trgdirect.com/FAQ.aspx . There is training built into the initial set-up fee and additional training available via the Jump Start program. Additionally, the TRG Help Desk is staffed with licensed customs brokers who can assist you with questions throughout the process.
  • Are CPE credits are available for my webinar attendance?
    Not at this time however thank you for the suggestion. TBI will look into this possibility.
  • We have a minimal amount of imports per year. Maybe 100 or so. Is this worth the money to do this? We are buying more and more overseas.
    The decision to become a direct-filer relies on several factors, only one of which is money. For a calculation of what the savings will be for your company you can look at the Saving Calculator at http://www.trgdirect.com/SavingsCalculator.aspx . Since it sounds like your company is increasing its imports those savings could significantly increase over time. However, for a more detailed analysis of whether you are a good candidate for direct-filing contact Nan Sarich at (800) 685-6082 ext 119.
  • With direct filing, would we have the opportunity to file with FDA as well?
    Absolutely. The TRG Direct product is fully compatible with FDA.
  • Has there been any significant increase on CF28s from Customs to direct filers that you're aware of?
    No. We have had no reports of increased CF-28’s, or 29’s from current TRG Direct clients. If anything we believe that CBP has a higher degree of confidence in the accuracy of those entries filed directly.
  • Does this increase the importer's risk of exams, at least on the initial filing periods?
    Absolutely not. We have had no reports of increased examinations or other types of CBP cargo holds by TRG Direct clients.
  • I know from foreign NVOs that the additional fee for the 10 data elements would be maybe $10/$15 max. $35/50 seems excessive? Mike can you comment?
    You are absolutely correct $10-$15 is much more reasonable and I suspect that the $10-$15 would be a ‘discounted’ rate for larger clients. Until the 10+2 regulations are finalized and systems have been modified it is anybody’s guess as to how the rate(s) for this service will unfold.
  • What is the average time it takes to do an entry?
    Once you are familiar with the system standard 1-5 line entries take 2-3 minutes.
  • We are a shrimp importer, subject to Anti-dumping tariff. Can TRG Direct process anti-dumping tariff entries?
    It can. However, anti-dumping entries do not qualify for Remote Location Filing (RLF) at this time. So if you are filing the shrimp entries in your “home port” you can use the TRG Direct system. TBI is currently working with CBP to increase the number and types of entries that qualify for RLF.
  • In using your system, can we attach documents such as inventories?
    Yes, TRG Direct clients can upload their parts tables or master files into the TRG Direct system. This significantly reduces the time it takes to prepare an entry and helps immensely with consistency.
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