10+2 Program Update

Issue 01, January 7, 2008

The DHL Global Forwarding, Air Express International and Danmar Lines security filing working group has been dedicated to the review and collection of the required Security Filing data elements, nicknamed “10 + 2”, since the issuance of the Strawman proposal.

This working group consists of experienced ocean freight, air freight and customs brokerage personnel. The group is continuing their review with the recent published Notice of Proposed Rule Making (NPRM), published January 2, 2008, in detail to determine the most efficient and practical way to report the required data elements for vessel cargo destined to the United States.

The proposal has clarified that the “+2” data elements, vessel stow plan and container status messages, has been approved to be transmitted electronically through the Automated Manifest System (AMS). The current approved electronic data interchange systems for the importer security filing (remaining 10 data elements) are the Automated Broker Interface (ABI) and Automated Manifest System (AMS.)

The importer security filing, other than those shipments consisting entirely of FROB and goods intended to be transported in-bond as an IE or T&E, would be required to file 10 elements for each commodity at the lowest bill of lading level. CBP states in the proposal that the manufacturer (or supplier) name and address, country of origin, and commodity HTS number would be required to be linked to one another at the line item level. The MID will not be accepted in lieu of the manufacturer name and address.

The full NPRM can be viewed at,
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064803815bc. Importers are encouraged to review the detailed definitions of the required data elements in this proposal and continue their review of the collection of this data. If they wish they may file comments on this proposed rule making. The instructions for filing comments are outlined in the NPRM. Comments must be submitted on or before March 3, 2008.

10 Importer Security Filing Data Elements

1. Manufacturer (or supplier) name and address. Name and address of the entity that last manufactures, assembles, produces, or grows the commodity or name and address of the supplier of the finished goods in the country from which the goods are leaving. In the alternative, the name and address of the manufacturer (or supplier) that is currently required by the import laws, rules and regulations of the United States (i.e., entry procedures) may be provided (this is the information that is used to create the existing manufacturer identification (MID) number for entry purposes).
2. Seller name and address. Name and address of the last known entity by whom the goods are sold or agreed to be sold. If the goods are to be imported otherwise than in pursuance of a purchase, the name and address of the owner of the goods must be provided.
3. Buyer name and address. Name and address of the last known entity to whom the goods are sold or agreed to be sold. If the goods are to be imported otherwise than in pursuance of a purchase, the name and address of the owner of the goods must be provided.
4. Ship to name and address. Name and address of the first deliver-to party scheduled to physically receive the goods after the goods have been released from customs custody.
5. Container stuffing location. Name and address(es) of the physical location(s) where the goods were stuffed into the container. For break bulk shipments, the name and address(es) of the physical location(s) where the goods were made "ship ready" must be provided.
6. Consolidator (stuffer) name and address. Name and address of the party who stuffed the container or arranged for the stuffing of the container. For break bulk shipments, the name and address of the party who made the goods "ship ready" or the party who arranged for the goods to be made "ship ready" must be provided.
7. Importer of record number / FTZ applicant identification number. Internal Revenue Service (IRS) number, Employer Identification Number (EIN), Social Security Number (SSN), or CBP assigned number of the entity liable for payment of all duties and responsible for meeting all statutory and regulatory requirements incurred as a result of importation. For goods intended to be delivered to an FTZ, the IRS number, EIN, SSN, or CBP assigned number of the party filing the FTZ documentation with CBP must be provided. The importer of record number for Importer Security Filing purposes is the same as "importer number" on CBP Form 3461.
8. Consignee number(s). Internal Revenue Service (IRS) number, Employer Identification Number (EIN), Social Security Number (SSN), or CBP assigned number of the individual(s) or firm(s) in the United States on whose account the merchandise is shipped. This element is the same as the "consignee number" on CBP Form 3461.
9. Country of origin. Country of manufacture, production, or growth of the article, based upon the import laws, rules and regulations of the United States. This element is the same as the "country of origin" on CBP Form 3461.
10. Commodity HTSUS number. Duty/statistical reporting number under which the article is classified in the Harmonized Tariff Schedule of the United States (HTSUS). The HTSUS number is required to be provided to the 6 digit level. The HTSUS number may be provided up to the 10 digit level. This element is the same as the "H.S. number" on CBP Form 3461 and can only be used for entry purposes, if it is provided at the 10 digit level or greater.

Remaining 2 data carrier elements

Vessel Stow Plan
Under the proposed regulations, the vessel stow plan must include standard information relating to the vessel and each container and unit of break bulk cargo laden on the vessel. The vessel stow plan must include the following standard information: With regard to the vessel,

1. Vessel name (including international maritime organization (IMO) number);
2. Vessel operator; and
3. Voyage number.

With regard to each container or unit of break bulk cargo,

1. Container operator, if containerized;
2. Equipment number, if containerized;
3. Equipment size and type, if containerized;
4. Stow position;
5. Hazmat-UN code;
6. Port of lading; and
7. Port of discharge.

Container Status Messages (CSM)
The NPRM lists the proposed requirements for carriers to submit daily CSM based on certain events. For each CSM submitted, the following information must be included:

1. Event code being reported, as defined in the ANSI X.12 or UN EDIFACT
   standards;
2. Container number;
3. Date and time of the event being reported;
4. Status of the container (empty or full);
5. Location where the event took place; and
6. Vessel identification associated with the message.

We will keep you informed of further communication regarding the 10 + 2 program. If you have any questions regarding this matter please do not hesitate to contact your DHL Global Forwarding representative.