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Current Events
ISF
July 14th, 2016

What is ISF?
The Importer Security Filing (ISF), is a Customs requirement to transmit certain information to U.S. customs before your freight is put on a vessel bound for the U.S. This applies to all ocean importers. The effective date for the interim Final Rule was January 26, 2009, with a flexible enforcement policy that ended on May 13th, 2015. Customs is now in full enforcement of the program.

Purpose of ISF
This is another step in the Department of Homeland Security's (DHS) strategy to better assess and identify high-risk shipments to prevent terrorist weapons and materials from entering the United States.

ISF regulations mandate that the Importer, as defined by the interim Final Rule, or its agent, transmit via, the carrier Automated Manifest System (AMS) or Automated Broker Interface (ABI), ten (10) data elements per ocean house bill of lading to CBP 24 hours prior to lading goods on a vessel destined to the United States. Carriers must submit to CBP an additional two (2) categories of data elements (vessel stow plans and container status messages) via AMS 24 hours prior to vessel loading in a foreign port.

The data elements are described below. ISF and the Carrier Security Filing have different data elements that consist of two from the carrier and ten from the importer. These data elements are as follows:

Importer Elements for Importer Security Filing Information (ISF-10)
    1. Manufacturer Name and Address
    2. Seller Name and Address
    3. Buyer Name and Address
    4. Ship to Name and Address
    5. Scheduled Container Stuffing Location
    6. Consolidator name and address
    7. Importer of record number
    8. Consignee identification number (IRS, SSN, Customs- assigned, CBP encrypted ID)
    9. Country of origin where goods were manufactured, produced or grown
    10. Harmonized Tariff Schedule at minimum 6-digit level


PENALTIES
Penalties can be assessed at up to $5,000.00 per violation and up to $10,000.00 per shipment with a 6 year statute of limitations.

IMPORTANT UPDATE ON ISF ENFORCEMENT!
Effective for shipments on the water on or after June 30, 2016 CBP will operate as follows:

Except as noted below, CBP is viewing the Interim Final Rule(published November 25, 2008) as a final rule. Flexible requirements for certain data elements are retained.
  • Ports will initiate liquidated damage demands without Headquarters review
  • Ports will no long be required to grant three strikes or issue informal warnings to importers.
  • There is no change to cargo hold policy. Ports may impose holds and/or issue Liquidated Damages as they see fit.
  • Individual ports retain discretion to set policy as to what constitutes a timely ISF (e.g., 72 hours before arrival in U.S., 24 hours from departure).

    Please contact us for further information on compliance and how to avoid these hefty fines.

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