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10 + 2 Security Filing

10 + 2 Security Filing. Presented by: Gary Ryan Airport Brokers Corporation Seattle, WA. What We Know. The 10 + 2 additional data elements Proposed rules to come out by January 2008 The Security Filing is the importer’s responsibility CBP has said this is not “customs business”

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10 + 2 Security Filing

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  1. 10 + 2 Security Filing Presented by: Gary Ryan Airport Brokers Corporation Seattle, WA

  2. What We Know • The 10 + 2 additional data elements • Proposed rules to come out by January 2008 • The Security Filing is the importer’s responsibility • CBP has said this is not “customs business” • 10 + 2 is for security and not for commercial enforcement

  3. Keep in Mind • CBP states that their 2006 records show 35% of all importers are one time importers. It is hard to identify and train them. • 45% of all importers import 2 to 10 shipments a year. • Leaving 20% of importers importing over 10 shipments a year

  4. Reasons Why U.S. Customs Brokers Should be Filers • 15 years ago Customs did not think customs brokers would be here now • Customs brokers know the importers, at least 65% + • We can train our clients • We can explain what needs to be done and why • We can explain the additional costs and charges involved • We have an idea of the problems and will know how to correct them. We know how to correct items like manifest discrepancies

  5. Where Will Data Come from? • If the data was required on the commercial invoice, or other document(s), we can input it. We can not input what we do not have. • If the data was required on the commercial invoice, it would be part of the customs entry record, subject to fines and penalties. • Only the importer and their U.S. customs brokers will know the ultimate U.S. consignee. • We need the carriers Arrival Notice information to know items like cargo location to file the customs entry in advance • The importer and customs broker should have full information as to what was filed on the security filing prior to filing the customs entry declaration

  6. What We Do Not Know • Penalties for incorrect information • Need to correct or re-file for corrections • The extent to which the 10 + 2 data will be compared to customs entry data • How customs brokers will access 10 + 2 data to compare to customs entry. Will info be a problem for CBP? • How CBP will handle nominal importers of record and nominal consignees. Some bills of lading through AMS still do not show actual shipper or actual consignee. CBP has not been issuing penalties.

  7. Considerations • When will a decision for exam be made? Who will be told? (CY & CFS cargo) • Will the 10 + 2 data force overseas exams? • RPM Alerts – 100% Chance of “Yes” • 10 + 2 forcing VACIS alerts and intensive exams- ???? • Who will do the exams and where? • Who will control where the overseas exams will be done – Carrier, shipper, freight forwarder? • Who pays for the exam? • Will there be overseas storage or demurrage? • Who will invoice for the additional charges? • If an exam is one overseas, will CBP check for other items like WPM and trademarks? • More chance for theft & pilferage

  8. Terms of Sale • Should an importer change from ex-factory to FOB or CIF? • Will foreign suppliers want to change from FOB or CIF to ex-factory to avoid overseas exam costs caused by CBP prior to cargo lading? • Will carriers advance overseas exam charges? • Will letters of credit timeframes need to be extended to allow more time for exams? • Will additional exams, especially overseas, change cargo insurance rates?

  9. Problems for Customs Brokers • Obtaining and filing the data elements • Correcting security filings • With entry volumes, time and date differences, having staff available to file on time • Keeping in the customs entry process • Trying to explain to importers the additional costs for data input • Trying to explain to importers the additional exam charges they can not control • Training overseas offices, foreign agents and NVOCCs

  10. This is Not the End • Again, CBP and Congress would not be requiring the 10 + 2 data prior to lading unless they planned to use it to screen and scan cargo prior to lading. CBP has said they want to continue to “push back the borders”. • Homeland Security proposes a global trade database to hold everything from P.O.s to final disposition • CBP says there will be additional layering • The FDA, CPSC and ImportSafety.Gov will probably want more data, not less

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