C-TPAT members to get “10+2” report cards
The following is excerpted from today’s edition of the “American Shipper”.
U.S. Customs and Border Protection will issue the first “10+2” progress reports on May 10 to let importers and their agents know how well they are complying with the rule for submitting advance electronic data about their cargo shipments, Assistant Commissioner Thomas Winkowski announced Wednesday.
The report cards will be sent by e-mail to all parties that have submitted Importer Security Filings (ISF) for their ocean shipments since the rule went into effect on Jan. 26.
CBP originally intended to send the progress reports only to filers, which will then be responsible for separating the individual spreadsheets and sending them on to their various customers. Most importers are using third-party vendors, such as customs brokers, forwarders and compliance software providers, to file on their behalf.
In a new twist, the border agency will also begin issuing report cards directly to all importers that participate in the Customs-Trade Partnership Against Terrorism, Winkowski told the 20 industry representatives on the Commercial Operations Advisory Committee meeting in Washington.
Tier 3 members of the voluntary supply chain security program — those who have taken the most precautions to control their shipments — will begin to receive the progress reports within 30 days, followed by other companies in the program….
Sharing the reports with C-TPAT members is a response to the trade community’s request to receive more trade facilitation benefits in exchange for making security investments, Winkowski said.
Richard DiNucci, program manager for ISF, said CBP would eventually send progress reports directly to a number of large importers as well to make their lives easier….
The progress reports will measure how many ISFs a company filed per month, the on-time rate, whether CBP accepted or rejected the filing, and the overall accuracy for each of the data elements.
Alison Reichstein, customs operations and compliance manager for Hewlett-Packard Co., told CBP officials that the report cards need to be more detailed so that companies can drill down to the actual mistakes made on each shipment and correct them.
“Aggregate data won’t be sufficient to drive down to corrective action,” especially for high-volume filers, she said. And many service providers are at various stages of readiness to map the aggregate data to their individual transaction records in a unified report for their customers, she warned….
DiNucci said Customs’ systems have been able to process the high volume of data without any deterioration in performance.
He repeated that the rejection rate for inaccurate or incomplete ISFs has fallen to between 5 percent and 6 percent per day since the early days. Most of the errors that cause CBP to reject the filing are due to duplicate transmissions from filers who do not give the system enough time for a response before trying to resend. In other cases a filer may submit a form in test mode, receive an ISF transaction number and then resend the filing using the identification number. In a few cases, CBP has processed transactions twice. DiNucci said these are simple mistakes that can be easily corrected.
A small number of rejections involve invalid harmonized tariff numbers or city codes in address fields, which are considered simple data entry mistakes.
Another 4 percent to 5 percent of “10+2” filings are accepted with warnings, meaning that 90 percent of the filings overall are coming in clean.
“The thing we’re not seeing is rejections because the data elements are not there,” which means filers are able to pull together the information they need in a timely fashion, DiNucci said.
Only 3 percent to 5 percent of filers are taking advantage of the unified filing option, which gives importers the ability to piggyback their customs entry data onto the ISF filing, he said.
And less than 1 percent of filings take advantage of the flexible arrangements that allow shippers extended time windows to update certain of the data elements that are difficult to obtain, such as container stuffing location and consolidator. Those data elements are usually being submitted correctly the first time, he added.
