Monday, January 21, 2008

10 + 2 Open Thread Experiment

This is an experiment in Wiki blogging.

Customs and Border Protection's Notice of Proposed Rule Making on the Importer Security Filing (so-called 10+2) is creating a big splash as people try and sort out exactly what will be required and what will happen in the case of non-compliance. Certainly, the requirements will create additional data to be collected and transmitted. Some of that may be burdensome. There are also concerns about the protection of business proprietary information.

I have some practical questions.
  • How is your company reacting?
  • How difficult do you expect compliance to be?
  • Can you quantify the difficulty in terms of time or expense?
  • What do you view as the most onerous part of the proposal?

Leave an anonymous comment here. Try and use this space for a discussion. Maybe acting as a group we can shed some useful light on the proposal.


Chris U said...

This will be prove quite interesting, for what I believe are several reasons:

If this is enacted, which it sounds like it will be, this could allow CBP to enforce this immediately, or effective in the very short term. This in turn, could lead to disruptions in the supply chain that could have tremendous consequences, akin to work stoppage or strike at one of the larger ports of entry. Importers scramble to meet this new requirement leading to delays.

What is interesting is what is not spelled out so clearly - how is this data to be collected and analyzed? These points of data, most of which, in my opinion, are already supplied or collected in one fashion or another, are fairly straightforward. Doesn't import best practices suggest that all of this information would be readily available from the importer or shipper?

In terms of implementation, no real plan seems to have been laid out - will there be an interim? will there be testing? How detailed do the data points need to be? Will there be an XML stylesheet to be followed? Will data be collected manually?

I guess what I'm trying to say is that, like most things CBP related, this seems to raise more issues and questions than answers or reasons. I think I'm frustrated a little because this sounds like a band-aid plan to fix something else that should have been fixed in the first place.

Anonymous said...

I work is msc shipping company
i would like why it is so called 10+2. i have read and re-read my documents and i have no idea about it. can you explain pls

Larry said...

Sure. There are 12 data elements to be subitted. 10 come from the importer and 2 from the carrier. Hence, 10 + 2. That name is likely going to fade as people get used to Importer Security Filing.

Evertything is on hold while the new administration reviews pending regulatory changes. So we are in a bit of limbo at the moment.

pharmacy said...

INteresting aspects, I wonder if at the end it really would come down to this.