The Trade Bridge Blog

Regulatory Purgatory - It's a Maze

Here's a quick reference guide to the tsunami of new regulations that are besieging exporters and importers:

The Lacey Act Amendment - effective approximately April 1st, 2009

Automated Export System Filings - effective June 2nd, 2008

10+2 - Security Filing - pending final ruling

Consumer Product Safety - Effective November 12th, 2008

First Sale Valuation - effective August 20th, 2008

What is 10+2 Going to Cost Us?

Kudos to Jennifer Baxter, Gail Coad and Christopher Chan at Industrial Economics for digging deep to research what 10+2 is going to cost SMEs. They were retained last year by CBP to do an economic impact analysis of 10+2. On Mike Laden's recommendation, we had a lively, in-depth discussion today as they further researched how 10+2 might impact SMEs. It breaks down into these categories of cost: IT, research, changes in terms of sale, transmitting the security filing. And these costs depend upon the complexity of the supply chain, the level of automation, business style, degree of business process change and the costs charged by the broker or ABI service provider. I'll be putting all this information together into a presentation for the American Association of Importers and Exporters on June 3. Look for my upcoming SME importer survey results and the subsequent detailed analysis on the Trade Bridge web site as well.

10 + 2 Becoming a Reality - Get Prepared

10 + 2 is bearing down on us. The rule is now a Notice of Proposed Rule Making (NPRM) and in less than 60 days it is likely to be inevitable. For information on how to prepare your company for this change see Customs web site, the American Association of Exporters and Importers Alert, Trade Innovations' write-up, and any of the Trade Bridge International FAQs on 10+2: October 18th, 2007 webinar, June 7th, 2008 webinar. If you are considering direct-filing of your customs entries with TRG Direct you may automatically be prepared to comply with this new security rule. Contact the direct-filing experts for details.

What is 10? What is 2? What is 24?

Here are the 10 advance data elements to be required by "10+2" from the responsible party, the importer:

1. Manufacturer name and address
2. Seller name and address
3. Container stuffing location
4. Consolidator name and address 
5. Buyer name and address 
6. Ship to name and address   
7. Importer of record number   
8. Consignee number   
9. Country of origin of the goods   
10. Commodity Harmonized Tariff Schedule number (6 digit)

Here are the 2 additional advance data elements to be required by "10+2" from ocean carriers:

1. Vessel Stow Plan
2. Container Status Messages

Expect to have to produce this info 24 hours before the vessel is loaded.

10+2 Redux, featuring John Jurgutis, CBP

Trade Bridge members met with CBP this month courtesy of TBI, to hear about CBP's Security Filing (10+2). Members met in the San Francisco Bay area with John Jurgutis, a Management and Program Analyst for the Secure Freight Initiative. The seminar was simultaneously broadcast to a TBI SME webinar audience. Over 200 SME participants were engaged in finding out what CBP's latest Security Filing (10+2) means for them and their business operations. (The WCO also addressed the audience from Brussels but I'll discuss that topic in a later post.) This effort by CBP to talk directly to SMEs is part of their response to demands from the trade that "CBP needs to reach out and get our feedback." If you're interested in seeing the program materials check out this TBI page. Feedback to CBP can be sent to John Jurgutis.

Security Filing (10+2) Details Posted

All the Trade Bridge 10+2 & Direct Filing webinar-seminar info is available online now. Click here for the details.