CBP seeks recruits for 10+2 system test

U.S. Customs and Border Protection officials are urging importers and their agents to participate in an ongoing test of IT systems in preparation for a new cargo security rulemaking that will require businesses to submit a huge amount of data about their overseas suppliers and domestic customers.

The agency has developed a rule for an Importer Security Filing, commonly referred to as 10+2, to be transmitted 24 hours prior to vessel loading at an overseas port. The controversial rule will require importers or their agents to electronically submit 10 data categories of data about their manufacturers, logistics providers, customers and cargo, and liner carriers to submit stow plans and status messages for containers in their custody. 

Deputy Commissioner Jayson Ahern told reporters Monday the long-anticipated final rulemaking under review by the Office of Management and Budget could be issued in the coming days or weeks, but I don't think it's going to be many weeks.

In an address to the National Customs Brokers and Forwarders Association of America's mid-year conference in Washington, Ahern said the agency has received more than 55,000 proxy filings from volunteers participating in the Advance Trade Data Initiative, an 18-month test bed involving about 100 companies designed to figure out optimal formats and transmission methods for filing the required data.

The number of unofficial filings has grown from about 50,000 at the beginning of August. CBP is accepting the data feeds in the importer's preferred form during the test period, but will have hard and fast filing specifications when the rule goes into effect.

CBP on Sept. 17 released its third set of draft technical requirements for the proposed security measure as it takes industry feedback how to program its systems to best support the necessary messaging between CBP and individual companies.

John Jurgutis, a CBP official helping manage the program, said in a separate presentation that many companies are submitting their information ahead of the 24-hour deadline.

Ahern acknowledged that many of the informal filings that have gone smoothly are from companies with simpler supply chains, but he welcomed more participants with more complex supply networks to help speed up CBP's learning curve.

We want more people involved to get a better sense of how we move forward, he said.

Under ATDI, CBP has begun testing the use of a unique identifier number generated by its system as a form of confirmation that it has received the security filing, Jurgutis said. Industry has fought hard to obtain the feature in the filing process. The ISF number can then be shared with the ocean carrier so it can verify the data has been submitted before loading the container on a ship.

CBP inspection officers are starting to identify unmanifested containers by matching the bill of lading filed by the ocean carrier with the ISF number referencing the same shipment, Jurgutis said.

The ATDI program will also soon begin testing the use of Dun & Bradstreet numbers as a substitute for the actual name and address of the overseas manufacturer or logistics handler because of concerns that many unrelated companies in the same city have similar manufacture ID numbers or similar street names.

Jurgutis clarified that under "10+2" importers do not have to wait until their container has been packed to file the electronic form, but instead can list the location where the container is scheduled to be stuffed and file an amendment if the location changes.

Cindy Allen, a vice president at Argents Air Express in Detroit, pointed out that CBP will not issue a no load message if there is an incomplete, inaccurate or late ISF but instead will issue penalties for non-compliance because the agency wants to reserve cargo holds for containers that actually pose security concerns. 

Source: American Shipper