As we have discussed previously CBP will now be requiring Customs data filing known as Importer Security Filing (10+2) effective January 2010. Customs will be assessing penalties in the amount of $5000 per violation for non compliance. Non compliance includes non filing, tardy filing and inaccurate filing. We must file this data at least 24 hours prior to loading. Bear in mind that Europe is 12 hours ahead of the west coast and China is nearly one day ahead. We must have the necessary data at least three full working days prior to loading. Please allow extra time for weekends and holidays.
CBP has indicated that they will consider past record during the flexible enforcement period January 2009 to January 2010 when assessing penalties once enforcement begins in January 2010. Importers who do not file until the mandatory date will not be given any consideration.
Full enforcement is less than six months away. CBP has indicated that they will not move the date. For this reason I am recommending importers to begin filing as soon as possible. This will also give you time to sort out the glitches with your exporters and make sure they begin sending us all of the necessary data timely.
I have attached a worksheet that you can send me with a copy of the commercial invoice. I am also attaching the mitigation guidelines from CBP. Please call if you have any questions.
Mitigation Guidelines : 20090814135402689
Importer Security Filing Worksheet : isf worksheet
