Three months later, the United States, also known as security ISF importer or February 10 at full power. Many importers is not known, the consequences of failure, or simple delay implementation. Now, before the first deadline of January 26, 2010 in full compliance, the actual “high” for a day of action.
Importer Security Filing on the basis of legal-SAFE Port USA, 2006. Customs and Border Protection (CBP) Importer Security Archive decided 25 November 2008. Near the property 24 hours in advance (AMS) developed clear rules C-TPAT, Container Security Initiative (CSI) and other security measures to improve national and international security ISF.
January 26, 2009, all U.S. importers (ibid. amended by CBP for this section) are forced to submit electronic data 10, in addition to the bill of lading number, 24 hours before loading container and bulk cargo vessels at sea ports. Installation of ships and container status messages – Maritime Carriers also must be sent to the two pieces of data. This “2″ on February 10. The key is to not touch the ISF, AMS, and enter the customs bill House. “Time” key 24 hours based on AMS data presentation and container status messages.
From the beginning, there was some resistance on the part of importers and their suppliers / vendors, because technically ISF Incoterms many changes. Under the ISF for example, if CBP to send any society “no load” FOB cargo can not be loaded. Even if the operator meets all recognized under Incoterms their normal duties and shipping not “bar” and “free on board” to be considered.
The ISF information must be submitted only for all the deliveries to the sea or the United States, including the provision of a free trade agreement (FTA). For the transport of goods in transit or ZF only five of the 10 data elements must be submitted (please contact us if you are interested in my comparison chart of the distribution of the data elements for the delivery).
U.S. importers may provide this information to yourself, or hire an agent to do it for them. But what can certify these units for transmission in electronic form by the U.S. Customs AMS (normal and NVOCC operator) or ABI (Acting), send your presentation FIA. Obviously most ISF filings made through “agent-presentation” to be sent, as most custom entries filed a customs officer. Anyway, the wine gives rest entirely accurate and timely importer.
The best presentation of Web applications, supporting the ISF access level that allows both an electronic download or manual data entry by the sender (or a supplier / seller), and therefore the importer or customs broker to verify / change the data before it is transmitted. This is a very important aspect of this presentation will compare the habits of the United States entry into the FIA office to verify the accuracy of the data importer FIA.
Collection and submission of data ISF
Most of the required ISF information has historically not until the end of the chronology of events, such as export and trade documents are not available, usually released shortly after the cargo was loaded and placed in the street. For U.S. importers and suppliers to educate them abroad as part of the new information needs, and to develop a method for presenting this information or presentation tools on time. This “need” is important, and fined $ 5,000 for failure or delay can be issued.
Because of changes in the information and document flow ISF compliance requires U.S. Customs in “flexible reporting” and “flexible program” has ended January 26, 2010. That’s when the fines, penalties and “Do not” start message.
Flexible Reporting -
Manufacturer or supplier, origin, HTSUS (U.S. price) and the final destination of the goods is not known exactly 24 hours before loading. As of January 26, 2010 will not allow importing an initial response on the basis of knowledge or data, and present at time of delivery. Then you need to update the ISF accurate information, no later than 24 hours before arrival at the first U.S. port.
Flexible application -
CBP refrain from fines or contribution, provided that the importer “show goodwill” in the accurate and timely submission of the ISF during this period. CBP began issuing “certificates” documenting the accuracy and speed away and importers expect better observed.
“Flexible Reporting” and “flexible compliance” deadline is January 28, 2010, when CBP will begin issuing fines. And send a message through the media AMS “failed” Container “unloaded” at hand effectively.
FIA sanctions and mitigation
CBP has developed guidelines for the imposition and collection of fines and the FIA to investigate the possibility of a state of softening due to the severity of the penalty issued.
Disclaimer ISF and guidelines on fines and mitigation clearly written. CBP has provided, in its sole discretion, as well as a variety of actions, both in the assessment and treatment of alleged violations almost unprecedented. In fact, only CBP failed to claim a file, false or incomplete information and is considered as a violation of Importer Security; that is, the importer does not comply with U.S. import laws and regulations.
The first violation is punishable by fines and penalties (loss) $ 5,000 and can increase with subsequent violations. The most serious violations a distinct lack of representation and outright fraud.
Removed key actions are studied by ISF is a lack of communication, delay in delivery, delivery of false information, the latest information and is not a statement that the importer is not accurate.
Mitigating factors importers published:
Signs of progress in the supply of data in good faith under the ISF “flexible time”
Relatively low number of offenses in relation to total ISF application
MFS rejection due to reasons beyond the control of the importer (ie the parent must go to another port)
Business Data ISF bad or the provision of information on the other side, but in the adoption of international trade rules.
Cancellation and IAF can be done if the importer can demonstrate that he will not be able to believe that the data prior to sending and / or it would be logical that the information is correct, and the corrective action taken, examined. Up to 50% chance of good if the ISF Importer reduce C-TPAT.
Aggravating factor to be published:
MFS failure is intentional fraud, smuggling or violation of law or other restrictions on imports of support
According to the information that is wrong or injury to the same data
Some associated with the same error ISF
Disabled or refuse to cooperate with the investigation of possible violations of customs
You can find more information about the importer Security Archive, sanctions and mitigation and access to http://www.amsfulfillment.com solution.