Import Security Filing

Issue 12, April 14, 2008

We are certain you have been reading about the proposed Import Security Filing / 10+2 by CBP. There has been much written about this proposal; however, at this time there has not been anything finalized.

DHL Global Forwarding is not waiting for the final ruling to be announced. We have established a project team to review the proposal in the current format and look for solutions that will provide an easy implementation for our customers and DGF when the final rule is announced and a start date is provided by CBP.

Following are some details concerning the proposed ruling as it stands today.

The Notice of Proposed Rule Making in regards to 10 + 2, published on January 2, 2008, allowed the trade to publicly file comments regarding the proposed 10 + 2 or Importer Security Filing (ISF) until March 18, 2008. CBP has received numerous comments from the import trade (Importers, Customs Brokers, NVOCC's, Steam Ship Lines, Trade Associations, etc.). These comments can be viewed at http://www.regulations.gov/, docket #USCBP2007-0077 2.

CBP is now tasked with reviewing each and every comment filed as well as responding to each comment in the final rule. Due to the number of comments filed, there is a feeling within the market that it will be at least 90-120 days before there will be any additional updates or rule making provided by CBP.

One of the predominant concerns of the trade is timing with regards to gathering and reporting the required data elements within the scope of the proposed rule - 24 hours before cargo is laden aboard a vessel. Many respondents to the NPRM have requested CBP have a phased-in approach to allow all concerned parties time to properly prepare and gather the required details from their offshore suppliers and vendors.

We will continue to publish updates as things progress; we welcome your requests for communication to discussion the proposal and what we know to be our respective roles in this proposal as it stands today.

Thank you for your continued support of DHL Global Forwarding.

Sincerely,

Cas Pouderoyen
Sr. Vice President, Ocean Freight North America