10+2 Security Filing

Issue 032, October 2, 2007

In January 2007 U.S. Customs and Border Protection (CBP) published the Strawman Proposal for the Advance Trade Data 10+2. To view this Strawman proposal in its entirety, please link to: http://www.cbp.gov/linkhandler/cgov/import/carriers/adv_data_elements.ctt/adv_data_elements.doc. The proposal states the additional data elements requested will be used for security and enhanced targeting and are not intended for commercial or trade enforcement purposes.

As CBP continues to move forward with the Security Filing or “10+2” initiative, CBP has reviewed the comments received by the trade and has continued to work with the Commercial Operations Advisory Committee (COAC) members on this proposal. The Office of Regulations and Rulings has completed its initial work on developing the draft Notice of Proposed Rule Making (NPRM). Once CBP finalizes, the NPRM will be published in the Federal Register.

The Security Filing proposal requires submission of 10+2 specific data elements to be transmitted to CBP 24 hours prior to cargo being loaded onto a vessel bound for the U.S. Currently this proposal only deals with ocean freight. CBP has stated, in the future, similar data elements will be required of other modes of transportation.

The proposal requires the importer to provide 10 data elements. These 10 data elements are: manufacturer name and address; seller name and address; container stuffing location; consolidator name and address; buyer name and address; ship to name and address; importer of record number; consignee number; country of origin of the goods; and the 6 digit commodity harmonized tariff schedule number.

The other two required data elements, to be provided by the carrier, are: vessel stow plan and container status messages.

As the proposed 10+2 Security Filing NPRM is nearing publication, importers may wish to begin determining who in their supply chains has access to the proposed 10 data elements, and may also wish to determine who in the supply chain will have responsibility for making the 10+2 data available to the agent elected to transmit the Security Filing. Importers may wish to combine these Security Filing requirements with their import compliance requirements.

Daily Federal Register notices can be found by connecting to the following link: http://www.access.gpo.gov/su_docs/fedreg/frcont07.html

Sincerely,

Brian Lindholm
Executive Vice President and Country Head - USA