Transcript IES Template

Welcome
SBS Group of Companies
Neville Peterson LLP
Customs Regulatory
Review
November 6, 2008
SBS
Group of Companies
Agenda
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•
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Welcome & Introductions
CBP Trade Strategy – SBS
10+2 and Your Import Supply Chain - SBS
Customs Enforcement Priorities and How to
Cope – Neville Peterson
• Cocktail Reception
SBS
Group of Companies
CBP Trade Strategy
A Look At The Numbers
Post 9-11 trade facts between 2001 and 2007:
 Imported goods grew by more than 65% in
annual imported value.
 CBP processed approximately 10 million
inbound vessel containers and more than 31
million entries in 326 ports.
SBS
Group of Companies
CBP Trade Strategy
A Look At The Numbers - Continued
Goods were received by over 810,000
importers with the top 3,000 importers
accounting for 73% of all imported value.
The United States trades with almost every
country in the world with Free Trade
Agreements and Preferential Trade Programs
continuing to drive increases in the complexity
of trade laws.
SBS
Group of Companies
CBP Trade Strategy
A Look At The Numbers
So, what does this tell us?
As global trade continues to increase in volume
and value so does the complexity of managing
risk and security.
As a result, we see a shift in the language of
CBP’s strategic goals.
SBS
Group of Companies
CBP Trade Strategy
High Level Strategic Goals – Comparison of Five
Year Objectives
Objective
2005 – 2010
2009 – 2013
Preventing Terrorism
At Ports of Entry.
Facilitate Legitimate Trade
Into the United States and
Ensure Compliance.
2
Preventing Terrorism
Between Ports of
Entry.
Enforce U.S. Trade Laws
and Collect Accurate
Revenue.
3
Unifying As One
Border Agency.
Advance National and
Economic Security.
1
SBS
Group of Companies
Source: CBP Five Year Strategic Plans, FY 2005-2010, 2009-2013
CBP Trade Strategy
High Level Strategic Goals – Comparison of Five
Year Objectives
Objective
2005 – 2010
2009 – 2013
4
Facilitating Legitimate Intensify Modernization of
Trade and Travel.
CBP’s Trade Processes.
5
Protecting America
and Its Citizens
6
Modernizing and
Managing
SBS
Group of Companies
Source: CBP Five Year Strategic Plans, FY 2005-2010, 2009-2013
CBP Trade Strategy
A Deeper Look at Facilitating Legitimate Trade
Level 2
Objectives
2005 – 2010
1
Modernize
automated import,
export and passenger
processing systems to
improve risk
assessment and
enforcement
decision-making.
SBS
Group of Companies
2009 – 2013
Improve risk
assessment and
targeting based on
advance information
to identify and
facilitate compliant
imports.
Source: CBP Five Year Strategic Plans, FY 2005-2010, 2009-2013
CBP Trade Strategy
A Deeper Look at Facilitating Legitimate Trade
Level 2
Objectives
2005 – 2010
2
Utilize state-of -the
art technologies and
processes to leverage
resources and to
conduct
examinations of all
potential high-risk
cargo, conveyances
and passengers.
SBS
Group of Companies
2009 – 2013
Strengthen
partnerships with
the trade
community, other
U.S. government
agencies, and
international
organizations to
ensure compliance.
Source: CBP Five Year Strategic Plans, FY 2005-2010, 2009-2013
CBP Trade Strategy
A Deeper Look at Facilitating Legitimate Trade
SBS
Level 2
Objectives
2005 – 2010
3
Enforce all U.S. trade,
immigration, drug,
consumer protection,
intellectual property
and agricultural laws
and regulations at the
borders.
Group of Companies
2009 – 2013
Expand pre-entry
and post-release
verification
programs to reduce
cargo delays at the
border.
Source: CBP Five Year Strategic Plans, FY 2005-2010, 2009-2013
CBP Trade Strategy
So, what does this mean to
importers?
•Additional Complexity – programs such as the
proposed Importer Security Filing (10+2) will expand
import requirements and push them further upstream in
your supply chains. You will need to expand your
process with suppliers and third party logistics providers
to meet new requirements.
SBS
Group of Companies
CBP Trade Strategy
So, what does this mean to
importers?
•Stronger Emphasis from CBP on Enforcement and
Financial Penalties – CBP will utilize revamped
technology and better information to target noncompliant importers. Importer’s internal compliance
programs and record keeping processes will become even
more important than they are today.
SBS
Group of Companies
Importer Security Filing (10+2)
Importer Security Filing Defined
The Importer Security Filing (ISF) is an
electronic transmission of 10 data elements
sent by the importer or their designated
agent 24 hours prior to loading of
containerized ocean cargo at the foreign port
of lading.
SBS
Group of Companies
Importer Security Filing (10+2)
Proposed Penalty for Failure to Comply
If the principal (importer of record) fails
to comply with the proposed importer
security filing requirements, the
“principal and surety (jointly and
severally) would pay liquidated damages
equal to the value of the merchandise
involved in the default”
SBS
Group of Companies
Importer Security Filing (10+2)
The “10”
name
Ship to name
1 Manufacturer
6
and address
and address
2
Seller name
and address
Container
stuffing location
7
4
Consolidator name
and address
9
5
Buyer name
and address
3
SBS
Group of Companies
8
10
Importer of
record number
Consignee
number
Country of origin
of the goods
Commodity
Harmonized
Tariff Schedule #(6
digit)
Importer Security Filing (10+2)
The “2”
CBP will require ocean carriers to
provide two additional data sets to
complete the security filing:
Vessel Stow Plan
Container Status Messages
SBS
Group of Companies
Importer Security Filing (10+2)
Building the “10”
Managing Proactively Inside the Import Supply Chain
Manufacture
Sellers
Order Placement
Source
Buyers
Information Flow
Order Fulfillment
Ship/Import
Receipt/Distribute
Keys for Success
Map Import
Supply Chain
SBS
Group of Companies
Develop
Supplier
Profiles
Develop
Part/SKU
Database
Importer Security Filing (10+2)
Building the “10”
Managing Proactively Inside the Import Supply Chain
Keys for Success
Map Import
Supply Chain
SBS
Group of Companies
•Identify Stakeholders
•Confirm Document
Flows
•Identify Information
Gaps
Importer Security Filing (10+2)
Building the “10”
Managing Proactively Inside the Import Supply Chain
Keys for Success
Develop
Supplier
Profiles
SBS
Group of Companies
• Identify & Document
Complete Manufacturer
Addresses
•Identify & Document
Complete Seller Addresses
• Identify Container Stuffing
Locations
Importer Security Filing (10+2)
Building the “10”
Managing Proactively Inside the Import Supply Chain
Keys for Success
Develop
Part/SKU
Database
SBS
Group of Companies
• HTS pre-import
classification of parts
or SKU’s
Importer Security Filing (10+2)
The Role of SBS In This Process
The SBS Advantages:
• Our tool provides a globally accessible web
application – all stakeholders can have
controlled access.
• Our tool provides a means to maintain a
parts/SKU database tied to HTS classifications.
• We can manage and monitor supplier
performance in meeting these requirements.
SBS
Group of Companies
Importer Security Filing (10+2)
The Role of SBS In This Process
The SBS Advantages: Continued
• We can provide economical options for training
suppliers on the new process and requirements.
• We are able to integrate 10+2 data elements with the
ocean automated manifest system where required
• Deliver a highly integrated system
• We can leverage the information provided in this filing
to provide a higher degree of visibility to your global
supply chain.
SBS
Group of Companies
John Peterson
Neville Peterson LLP
SBS
Group of Companies
Data Element Definitions
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Manufacturer (or supplier) name and address. The name and address of the entity that last manufactured, assembled,
produced, or grew the commodity, or the 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 U.S. (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).
Seller name and address. The name and address of the last known entity by which 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.
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Buyer name and address. The name and address of the last known entity to which 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.
Ship to name and address. The name and address of the first deliver-to party scheduled to physically receive the goods
after the goods have been released from customs custody.
SBS
Group of Companies
Data Element Definitions
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Container stuffing location. The name and address (or addresses) of the physical locations where the goods were
stuffed into the container. For break bulk shipments, the name and address (or addresses) of the physical locations
where the goods were made "ship ready" must be provided.
Consolidator (stuffer) name and address. The 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.
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
purposes is the same as "importer number" on CBP Form 3461.
SBS
Group of Companies
Data Element Definitions
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Consignee numbers. IRS number, EIN, SSN, or CBP assigned number of the individuals) or firms in the U.S. on
whose account the merchandise is shipped. This element is the same as the "consignee number" on CBP Form 3461.
Country of origin. Country of manufacture, production, or growth of the article, based upon the import laws, rules
and regulations of the U.S. This element is the same as the "country of origin" on CBP Form 3461.
1HTS number at 6 digit level. Duty/statistical reporting number under which the article is classified in the HTS. The
HTS number is required to be provided to the 6 digit level. The HTS 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.
SBS
Group of Companies