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10+2 When Do We Get The NPRM?. Curtis Spencer, President IMS Worldwide, Inc. www.imsw.com. CBP’s Advance Data Project. Required by § 203 of SAFE Port Act of 2006 Also known as “10+2” or the Security Filing Consists of 10 pieces of information filed by the importer and 2 from the carrier

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curtis spencer president ims worldwide inc www imsw com

10+2 When Do We Get The NPRM?

Curtis Spencer, President

IMS Worldwide, Inc.

www.imsw.com

cbp s advance data project
CBP’s Advance Data Project
  • Required by § 203 of SAFE Port Act of 2006
  • Also known as “10+2” or the Security Filing
  • Consists of 10 pieces of information filed by the importer and 2 from the carrier
  • Applies to ocean freight only (for now)
  • Must be filed at least 24 hours prior to loading at foreign port
  • In addition to the currently required advance manifest data
  • See next page for the 10+2 elements
slide3

DATA ELEMENTS

  • Data elements provided by the Importer of Record:
    • Manufacturer name and address
    • Seller name and address
    • Container stuffing location
    • Consolidator name and address
    • Buyer name and address
    • Ship to name and address
    • Importer of record number
    • Consignee number
    • Country of origin of the goods
    • Commodity Harmonized Tariff Schedule number (6 digit)
  • Data elements provided by the carrier:
    • Vessel Stow Plan
    • Container Status Messages
status of 10 2
Status of 10+2
  • 10/06 – Legislation signed by President
  • 11/06 – Requested consultation from Commercial Operations Advisory Committee (COAC)
  • 2/07 – COAC submitted recommendations
  • 2/07 – Begin drafting Notice of Proposed Rulemaking (NPRM) in CBP
  • 8/07 – To DHS (almost out)
  • 9/07 – To OMB
status of 10 2 cont
Status of 10+2 (cont.)
  • Next steps:
    • Final NPRM draft is at DHS, then to OMB
    • Complete cost/benefit and feasibility studies
    • Publish NPRM with 90 day comment period
    • Receive and analyze comments
    • Publish Final Rule in Federal Register
    • Implement program (see next page)
status of 10 2 cont6
Status of 10+2 (cont.)
  • Current status
    • NPRM nearly done in DHS
    • Cost/benefit and ATDI test program complete by time of NPRM publication
    • Estimated date of publication of NPRM: Late-Fall 2007
  • No current discussions allowed with members of COAC or any other in the trade.
  • Do not know how many of the 37 recommendations were accepted (13??)
implementation phase
Implementation Phase
  • First step: Trial using volunteer parties (not official but part of COAC recommendations)
  • Phase-in period of up to one year
    • Applies to everyone
    • Customs will use informed compliance approach to dealing with non-compliant filers
  • After phase-in period becomes mandatory, all data must be filed for all shipments
implementation mechanics
Implementation Mechanics
  • Importer of record is responsible for filing
    • Can appoint agent (such as customs broker) to perform filing on its behalf
    • CBP will not regulate who is authorized
    • Still looking at 1 filer vs. 2 filers on same SF
implementation mechanics9
Implementation Mechanics
  • Data elements will be filed through ABI or AMS (or other, maybe)
    • Filers limited to importers, carriers and brokers or others who may qualify
    • COAC recommended filers be expanded to include foreign freight forwarders
  • Filing must be done by a single party
    • Information may be obtained from multiple parties
implementation issues
Implementation Issues
  • Missing/incomplete/inaccurate data?
  • Amending the security filing
  • Issuing no-load messages
  • Unauthorized filers
  • Proprietary information
  • Cost/benefit & feasibility studies
  • “Customs business”?
  • Manufacturer not known
  • Consistency with WCO
some coac recommendations
Some COAC Recommendations
  • CBP should issue electronic confirmation that filing has been accepted
  • Filing can be satisfied by filing CF7501 data or CF3461 data plus 2 elements
  • Time period for filing entry be pushed back to any time after departure from last port
  • CBP should identify exempt transactions
  • Importer should have ability to view filings on its behalf on-line
  • COAC must remain engaged during development and deployment stages
more coac recommendations
More COAC Recommendations
  • CBP should issue electronic confirmation that filing has been accepted
  • Filing can be satisfied by filing CF7501 data or CF3461 data plus 2 elements
  • Time period for filing entry be pushed back to any time after departure from last port
more coac recommendations13
More COAC Recommendations
  • CBP should identify exempt transactions
  • Importer should have ability to view filings on its behalf on-line
  • COAC must remain engaged during development and deployment stages
more coac recommendations14
More COAC Recommendations
  • CBP will accept “filing of the 214” in place of entry, entry summary on all such suggestions
  • Time of filing amendment will be prior to entry “or admission”
  • COAC to review second “straw man” prior to NPRM (not accepted!)
  • Cost-benefit analysis to use industry best practices, prior to NPRM
conclusion
Conclusion?
  • 10+2 will be the 24-hour rule, on steroids!!
  • The issue of “single filer” may become contentious and a real issue
  • Timing of the data needed is key to multiple filers
  • Watch for the “hammer” at the 13th month
  • This is a “paradigm shift” for the importing community
  • Experts agree: 2-3 days delay in the supply chain
questions answers

Questions & Answers

Curtis Spencer, President

IMS Worldwide, Inc.

www.imsw.com