10+2 is a new requirement for all importers of ocean cargo. This represents an enormous change in importing. For the first time, a pre-laden entry will have to be submitted to CBP at least 24 hours prior to the loading of cargo on a U.S. bound vessel. This entry will require the filers to have advance copies of invoices, the container number, the stower and the stuffer of the container. There is more about it here:
http://www.cbp.gov/linkhandler/cgov/trade/cargo_security/carriers/security_filing/ra.ctt/ra.pdf
Penalty for non compliance will be $5000 per Import Security Filing (ISF). All importers of ocean cargo must comply regardless of size and number of imports. Importers can file the data themselves if they have access to the CBP computer system or rely on an agent. Henry E. Kloch & Co. will be willing to file ISF’s for importers for a fee as this represents a pre-laden entry that is separate from the import entry. The new requirements go into effect 01/26/09 but full enforcement including penalties for non compliance begin 01/26/10. CBP is allowing the year to give the importing community time to comply. It is crucial to get suppliers to begin sending the required elements as early as possible and no later than several days before loading the vessel. It will also be crucial for freight forwarders to issue bill of lading numbers and shipping instructions several days before loading. The are encouraging importers to begin transmitting data as soon as possible after January 2009.
One of the more radical requirements is that ALL importers have a continuous bond. It appears that the new requirements will make single transaction bonds unusable for ocean cargo. If an importer does not have a continuous bond now, we would encourage them to apply for one by this summer.
I attended a seminar today and here is a copy of the materials provided December 09 10+2 Seminar
