Since the beginning of Importer Security Filing (10+2), US importers have struggled with complying and with the recent January 26th enforcement date, many are still trying to find the silver lining in their ISF compliance. In a webcast sponsored by Integration Point, Virginia Thompson, Manager – Import/Export Operations and Trade Compliance at EuroMarket Designs, Inc. (d/b/a Crate & Barrel), shared how her company is making 10+2 work for them.
During the webcast there were several topics many people had questions about. Over the next few weeks, we will be posting those questions and the answers from Virginia Thompson here.
These questions deal with getting other supply chain partners to cooperate with ISF regulations and filing time.
Q: We have challenges getting our vendors, suppliers, shippers, etc to participate. How can we put pressure on them to file ISFs?
A: The reality is that not all parties are going to be as compliant as you’d like. We have done a couple of things – added into our vendors operations guide a whole section about ISF and informed them if we have any CBP penalties for ISF filings that are due to late or inaccurate information from them, they are responsible for those penalties. We have also implemented a late ASN filing fee, so if they send the ASN late, even if we don’t get hit with a penalty from CBP, we are going to charge them a small fee for late filing. We know that even if we avoid a penalty from CBP, it’s not making our numbers look good.
Q: How can you tell if the AMS BOL data timeliness is the fault of the supplier or forwarder? How do you know who to go after?
A: This is definitely something we’ve struggled with. The only answer I can give is to have good communication and work with parties whom you trust. At the end of the day, you have to develop a good relationship with your business parties. We’ve had a number of conversations where the vendor comes to us and says the freight forwarder didn’t give me the BOL number and we ask them to prove it so they send us the email they sent. And we look at the email and they’re right, the forwarder didn’t give the right BOL number. So asking for documentation is important when you have a “he said, she said” situation.
The other thing we’ve worked up with a number of our freight forwarders is a specific form that we developed in Excel that they are to give our vendors with the appropriate information. In many cases they’re also giving them the stuffing location and consolidator information so this form has those data fields on it. We specifically designed this form not to capture all the other BOLs because if your forwarder is not automated, there may be 3 different BOL numbers out there (master bill, house bill in AMS and a house bill that prints on the BOL copy). We took off the other BOL numbers that we didn’t want to see and only asked them to fill in the AMS house BOL number. So one of the ways we are auditing this is by asking the forwarder to prove that they sent the form to the vendor and when, or asking the vendor to prove that the forwarder did not send it. So we are really trying to get into the details and specifics of the situation.
Q: Our fright forwarder is filing our ISFs, but ensuring accuracy of the data is something we need to own as the importer. We are still having problems getting the forwarder to provide exception reports for shipments that don’t have ISF filed. Any thoughts on this?
A: I wish there was such a thing as an arrival notice for ISF because then you would know what’s out there that has to be filed for. If you have a robust transportation management system that all your vendors use, then you’re fine. We don’t have a system like that but we may look to implement it over the next couple of years. For right now, you can look at the purchase orders because they have dates that goods are supposed to ship. But, those dates may not end up being exact. We have done a couple of things – we have some transportation providers that are starting to send us notices when something is laden on board and there is no ISF filed. The only problem with this approach is that sometimes it’s a timing issue. So we are spending a lot of time looking this up. Another thing we’re doing is a manual final check at the point of receiving shipping documents (usually a couple of days after something ships) to make sure an ISF is filed. Unless you have one forwarder who is moving all of your goods and you have them do your reporting, this is difficult.
Do you have questions about ISF enforcement? Feel free to post your questions here using the comment box. We will be happy to reply. Also, if you missed the webcast, you can view it on-demand here.
As part of its continuing effort to reduce paperwork and respondent burden, US Customs and Border Protection (CBP) is accepting comments on C-TPAT information collection requirements. Organizations participating in the C-TPAT program benefit from reduced inspections and increased compliance and security throughout their supply chains.
CBP encourages the general public as well as Federal agencies to submit comments that address the following:
- Whether the collection of information is necessary
- The accuracy of the agency’s estimates of the burden of the collection of information
- Ways to enhance the quality, utility and clarity of the information to be collected
- Ways to minimize the burden
- Annual costs to respondents from the collection of data
Written comments should be addressed to US Customs and Border Protection, Attn: Tracy Denning, Office of Regulations and Rulings, 799 9th Street, NW, 7th Floor, Washington, DC 20229.
Automating the collection of information is one way to minimize the burden of submitting it. Integration Point C-TPAT provides electronic collection, standardization and organization of supplier data, allowing the user to effectively collect information required for C-TPAT certification. For more information on how to simplify validation with CBP, visit the Integration Point website.
Walt Disney World will be filled with more than cartoon characters when the International Compliance Professionals Association (ICPA) holds their seventh annual conference in Orlando, FL. The pirate-themed conference is being held March 14 – 18 and will cover trade topics important to both novice and experienced compliance professionals.
The conference will be broken down into import and export tracks. Topics include:
- NAFTA
- How to use ACE Reports Effectively
- Product Safety
- IOR Management
- Training Employees on Export Control
- Export Control Violations
Already planning to attend? Make sure you stop by the Integration Point booth (#32) for a global trade management treasure map and the chance to win a Flip video camera. For more information and to register, visit the ICPA website.
Next week Austin, TX will be filled with petroleum exports for the American Petroleum Institute (API) International Trade & Customs Conference.
The conference is designed to provide attendees with up-to-date information on what is happening in international trade in the areas of duty drawback, imports, exports and US foreign-trade zones (FTZ). Being held March 8 – 10, the conference includes a broad range of topics that will be presented by experts in the field of petroleum operations and customs laws and regulations. Session topics include export compliance, legislative issues, FTZ optimization and ACE updates, presented by Melissa Irmen from Integration Point, Inc.
For more information and to register, visit the API website.
Since the beginning of Importer Security Filing (10+2), US importers have struggled with complying and with the recent January 26th enforcement date, many are still trying to find the silver lining in their ISF compliance. In a webcast sponsored by Integration Point, Virginia Thompson, Manager – Import/Export Operations and Trade Compliance at EuroMarket Designs, Inc. (d/b/a Crate & Barrel), shared how her company is making 10+2 work for them.
During the webcast there were several topics many people had questions about. Over the next few weeks, we will be posting those questions and the answers from Virginia Thompson here.
Today’s questions center around self-filing.
Q: How did you decide you wanted to self-file?
A: We didn’t decide we wanted to self-file, we decided we wanted to use the tool offered by Integration Point. We decided that was going to be the best way of meeting ISF compliance for us, and that simply meant self-filing. It’s not like we set out to self-file, it was really what is the most cost effective and efficient way of becoming compliant with ISF and that was through using Integration Point 10+2 and so by default, it meant self-filing. 20/20 hindsight, I’m glad we ended up in this situation because it has given us more control. For example, we’ve never had the issue of going to the agent or broker – we have access to all that data because we’re doing it ourselves.
Q: In passing electronic data around, are you providing your federal ID to off shore entities?
A: Absolutely not. That is one of the reasons we like the self-filing solution because we are controlling all of the data. Through the Integration Point portal, we can manually key the ISFs and create users (like vendors) to come in and create them. There are ways of protecting certain fields so they can’t see your IR number. But at the end of the day, since we’re filing them all through the data we’re creating, we don’t have to share that with anybody, so we don’t.
Do you have questions about ISF enforcement? Feel free to post your questions here using the comment box. We will be happy to reply. Also, if you missed the webcast, you can view it on-demand here.
There is one common goal that all global traders should be working towards – making a positive impact on your company’s bottom line. A list of the top 10 critical tasks everyone should be undertaking to ensure success in 2010 was created by Beth Peterson Enterprises (BPE).
“With the beginning of 2010, everyone has the opportunity to start fresh in their global trade compliance initiatives,” noted Beth Peterson, President, BPE. “It is imperative, now more than ever, that the trade industry comply with global rules and regulations. While this list is not inclusive, it should enable compliance professionals to give a meaningful start to the new decade.”
Take the time to double check that your company is following these tasks:
- Review and/or develop objectives for the year
- Review contracts to ensure there are no barriers to achieving those objectives
- Develop or update your global risk analysis
- Establish an audit schedule for the year
- Identify training and educational requirements for the company, your team, yourself and your service providers
- Review the legislative landscape for pending regulations that will impact your company
- Meet with your sales and marketing team to understand their strategies for 2010
- Meet with your supply chain strategy team to identify new strategies or plans for 2010 that will require global trade compliance support from a planning perspective
- Review your compliance manuals and identify any processes, policies or procedures that require development or updating
- Finalize your annual budget
For more detailed information, visit the BPE website.
On the first Tuesday of each month, helpful tips for players in the global trade industry will be posted on Global Trade News blog.
Respondents to an Aberdeen study on Global Trade Compliance Priorities had an average trade compliance error rate of 25.7% on their international orders. For an importer with 1,000 entries per year, that’s 257 entries with errors. In the same report, Best-in-Class organizations had fewer errors (less than 4%) and incorrect duty payments (less than 5%) – why? Because these companies have streamlined their entire import cycle in order to eliminate these common entry errors and verify the import data at every step in the import process.
- Close the loop in your import process. The import process begins with the creation of the purchase order (PO) and ends with post-entry validation. A Best-in-Class organization is constantly managing each phase of this process – does the information on the PO match the classification database, does the commercial invoice match the PO and the classification database, does the broker have the correct classification information to verify the entry before filing, and finally, is the entry put through a complete post-entry validation? By checking import data at every step in the process (PO to post-entry) Best-in-Class organizations have fewer errors on entries, and therefore, have a more streamlined and compliant import cycle.
- Check more than just product classifications. At the invoice level, companies should verify more than product classification data. A Best-in-Class company certifies that the quantity and value of the invoice matches the transaction value on the entry, the PO, the information stored in global classification system, and what was paid to the trading partner.
- Verify free trade agreement eligibility within organizations and with brokers. To fully close the loop, the import process requires more than just correctly flagging products in a classification database for free trade agreement eligibility. The products must also be flagged on the entry by the broker, in order for the importer to realize duty savings for all qualified products. By auditing all entries for inaccuracies as part of a post entry audit program, the importer is minimizing the possibility of lost duty savings.
Visibility into the supply chain is critical to managing the pre- and post-entry process. Using Integration Point Entry Visibility, importers can check the data in their entries to verify that classification data is correct, applicable free trade agreement benefits are utilized, and quantities used to calculate duties are accurate. Entry visibility assists with post-entry processes by quickly identifying entries requiring updates and facilitating corrections and adjustments.
Since the beginning of Importer Security Filing (10+2), US importers have struggled with complying and with the recent January 26th enforcement date, many are still trying to find the silver lining in their ISF compliance. In a webcast sponsored by Integration Point, Virginia Thompson, Manager – Import/Export Operations and Trade Compliance at EuroMarket Designs, Inc. (d/b/a Crate & Barrel), shared how her company is making 10+2 work for them.
During the webcast, there were several topics about which many people had questions. Over the next few weeks, we will be posting those questions and the answers from Virginia Thompson here.
This first set of questions focused on CBP’s involvement with ISF.
Q: In general, how does an importer demonstrate to CBP that they are making satisfactory progress towards compliance?
A: Eventually CBP is going to start looking at the accuracy of data which is mostly going to come from comparing it to your entry. You want to see your accuracy increasing in a steady formation over all of 2009 and 2010, even in you’re not 100% compliant yet. Not that it would be bad to have it go up very quickly towards 100% compliance, but I think as long as it’s heading up, that’s really what you need to be doing. The other thing I would recommend is that if there are any questions or problems you have in a particular situation, contact CBP. Whether you’re talking to your ABI representative or sending questions to the CBP ISF mailbox (Security_Filing_General at cbp.dhs.gov), letting them know the problems you’re facing is something that in the future, if you’re facing a situation where they’re suggesting liquidated damages are on the line, you can say we have been trying and we told you we were trying. That will be very important.
Q: How do you obtain a progress report from CBP?
A: The progress reports are sent automatically to anyone who is Tier 3. If you are Tier 3 and you’re not receiving your progress reports, you should contact CBP. If you’re not Tier 3, then the progress reports should be coming to the filer if they’re being requested. If you are not the filer, you will need to ask for a copy of your progress report. A freight forwarder, who is filing for thousands of importers, will get everyone’s data together and it’s their responsibility to break it up. What the report shows is interesting but not all that useful. It shoes a very high level percentage broken down by months, like timeliness of filings, how many rejections and errors you had and what type of errors. The most common type of error is duplicate filings. This is when two different parties are filing an ISF on your behalf or you accidentally submitted two ISFs for the same BOL number. The main problem with the data is that it isn’t transaction specific. You can see you have six different duplicate filings but not which six ISFs were duplicates. For us that’s not a problem because we have all that data in the Integration Point tool, but if you are using a third party to file your ISFs, you will have to work with them for some kind of reporting mechanism for them to tell you when you have a duplicate filing, late filing, etc. If nothing else, it gives you an idea of what Customs is looking at when they look at you as an importer, but it doesn’t give you specific information to go back and enter corrections.
Q: How does CBP match the house bill used on an ISF filing with the master bill used on an entry?
A: If there is a house bill, then your entry is probably filed at the house bill level, which is also the level at which your ISF is going to be filed. If there is no house bill, then it will be filed at the master (or straight) bill and that will be the same BOL number. My understanding is that’s why CBP wrote the ISF regulations in terms of what BOL level to be submitted, because they’re trying to make it match the one at which most entries are filed.
Do you have questions about ISF enforcement? Feel free to post your questions here using the comment box. We will be happy to reply. Also, if you missed the webcast, you can view it on-demand here.
Until this week, a Social Security Number (SSN) was required as an identifier number when registering to file and filing electronic export information (EEI) in the Automated Export System (AES). Issued in a final notice, the US Census Bureau has introduced an Employer Identification Number (EIN) instead.
In accordance with the Privacy Act of 1974, authorized agent’s social security numbers will now be protected. AES will no longer provide the option for using a SSN as an identification number. The EIN is not as sensitive of information as a SSN and does not have an expiration date, so it can be used indefinitely. EIN’s may be obtained through the IRS website, free of charge within 15 minutes. This rule goes into effect on March 24, 2010.
If your company exports or wants to start exporting, and needs information about AES and the requirements for filing, visit the Integration Point website for more information. By integrating AES filing capability with the entire Export Management suite of products, companies can guarantee proper validation of all the required pieces of an export shipment such as Schedule B number, ECCN, unit of measure, etc.
Recently, South Korea has taken an aggressive approach to forming free trade agreements (FTA) with countries around the world. To help companies trading best utilize these FTAs, Integration Point, Inc. has formed a strategic relationship with Samjong KPMG Advisory, Inc., solidifying both companies as the leading providers of free trade agreements for the South Korean market.
South Korea currently has 14 FTAs either signed, in process or under joint study. In the next 10 years, South Korea is expected to sign free trade agreements with more than 60 countries, making South Korea a true “hub” of FTA activity.
The Integration Point – Samjong KPMG Advisory relationship will provide unmatched capabilities to companies looking to leverage FTA benefits, as well as automating compliance of existing FTAs such as
- Korea – India
- Korea – EU
- Korea – ASEAN
- Future FTAs being negotiated (such as Korea – US)
Integration Point Free Trade Agreement Management software automates the process of soliciting suppliers and determining product eligibility based on free trade agreement, preferential agreement and preference programs around the world. Integration Point Free Trade Agreement Management software will also generate certificates of origin for customs agencies based on eligibility criteria, analyze Bills of Materials against multiple FTAs and access up-to-date global FTA rules in an on-demand environment. For more information on Integration Point FTA Management, visit the Integration Point website.
