ing confirmation, or require their suppliers to undergo training in ISF compliance.
5. Give CBP everything you’ve got, as
soon as you’ve got it. Sometimes it’s simply
not possible to obtain every piece of data
within the required time frame. “Send
what you have, even if you don’t have a
bill of lading number yet,” advises
Peterson. “Make sure what you do send is
timely. You can update it as soon as you
get additional details.”
So far, she says, importers that commu-
nicate with Customs authorities and can
demonstrate that they’re making an hon-
est effort to get the information and
resolve any problems are “not feeling a lot
of pressure. … Customs has been true to
its word” that it will take those efforts into
consideration when assessing compliance
levels.
6. Automate, automate, automate. That’s
the message from vendors of global trade
management (GTM) software. Although
they have an obvious interest in promoting automated solutions, they do have a
valid point, especially in regard to ISF filings. With so many parties now involved
in providing data and with tighter deadlines to meet, using software to standardize data collection and formatting is a
huge time saver. It can also promote accuracy, minimize errors, and avoid duplication of effort. On top of that, the software
can identify information gaps, provide
greater visibility into overseas activities
and costs, create a compliance audit trail,
and improve data integrity throughout
the supply chain.
Don’t let your guard down
Since 10+ 2 has been in effect, importers
have experienced numerous glitches, surprises, and holdups, caused mostly by
inaccurate, conflicting, missing, or late
information. They have also seen their
order-to-delivery cycle times stretch by an
average of two days, according to a survey
conducted by American Shipper magazine
and BPE Global.
Thanks to regular communication
between the trade community and CBP,
and to hard work by organizations like
AAEI and CBP’s advisory councils, many
of those issues have been resolved—or at
least they’re on the agency’s radar screen.
In fact, the trade community has
done remarkably well in meeting the
complex ISF requirements. In a July
23 letter to 15 industry organiza-
tions, CBP Commissioner Alan
Bersin wrote, “To date, CBP is very
satisfied with the compliance levels
of the trade community.”
Even if you’re confident your com-
pany merits such praise, that doesn’t
mean it’s safe to let your guard down.
Instead, use the six suggestions
offered here to make sure that when
it comes to ISF compliance, you, your
suppliers, and your service providers
are all following best practices. ;
