fastlane
when 10+ 2 doesn’t equal 12
UNLESS YOU’RE INVOLVED WITH INTERNATIONal cargo shipping, you can be forgiven for thinking
that “ 10+ 2” simply equals 12. From what I gathered at
the recent conference of the Council of Supply Chain
Management Professionals, the term—which refers to
a cargo security initiative that took effect in
January—has yet to gain universal recognition. While
many conference attendees had at least a passing
familiarity with the term, there were plenty of others—particularly those who deal largely with domestic shipping—who didn’t seem to have a clue.
The lack of awareness can’t be put down to a scarcity of information. A fair amount has been written
about 10+ 2, particularly by those who are involved
with it. Nonetheless, a surprisingly large number of
supply chain practitioners appear to be vague on the
details. This, then, will be an attempt to explain 10+ 2
to those who are interested—to those of you who
aren’t, now would be a good time to flip the page.
Officially known as the Importer Security Filing
(ISF) and Additional Carrier Requirement, the 10+ 2
rule is intended to help the U.S. Bureau of Customs
and Border Protection (CBP) screen incoming ocean
containers for security risks. About 7 million containers are unloaded at U.S. ports each year, each offering
a potential opportunity for terrorists and smugglers
to bring dangerous or banned material into the country. CBP believes that by gathering information about
these imports before they arrive on U.S. shores, it will
be better able to target high-risk shipments for further inspection.
Under the rule, both importers and carriers must
submit specific information on the cargo prior to its
arrival in the United States. Importers are responsible
for providing 10 data sets for each container; ocean
carriers are required to provide two additional sets—
hence the name “ 10+ 2.”
Importers must submit their data to CBP electronically 24 hours before a container is loaded onto a
ship bound for the United States (with two exceptions, noted below). This is the ISF transmission and
consists of:
1. Name and address of seller
2. Name and address of buyer
3. Importer of record number
4. Consignee number
5. Manufacturer or supplier
6. Ship-to party
7. Country of origin
8. Commodity Harmonized Tariff Schedule number
9. Container stuffing location*
10. Consolidator name and address*
Carriers are responsible for providing the last two
data elements, which they must do no later than 48
hours after the ship’s departure from the port of ori-
gin. The elements are:
1. The vessel stow plan
2. Container status message data, which must be
provided within 24 hours of
the time the information is
entered into the carrier’s
equipment tracking system.
To further complicate
matters, there is the issue of
containers that remain on
board after cargo is discharged at a U.S. port. For
this cargo, five data elements must be transmitted
24 hours prior to loading. These are:
1. Booking party name and address
2. Ship-to party
3. Commodity Harmonized Tariff Schedule number
4. Foreign port of unloading
5. Place of delivery
Although importers and carriers have already
developed methods of gathering and transmitting
data that ease the burden, it’s clear that complying
with 10+ 2 is a cumbersome procedure. What’s not so
clear is whether all that effort is justified for an initiative whose effectiveness, I believe, is questionable.
*This information is not required before loading but must
be provided no later than 24 hours prior to the container’s
arrival at the port.
Clifford F. Lynch is executive vice president of CTSI, a supply chain solutions firm; author of
Logistics Outsourcing – A Management Guide; and co-author of The Role of Transportation
in the Supply Chain. He can be reached at cliffl@ctsi-global.com.
