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By Clifford F. Lynch
DC Velocity, November 2009
Unless you’re involved with international cargo shipping, you can be forgiven
for thinking that "10+2" simply equals 12. From what I gathered at the recent
conference of the Council of Supply Chain Management Professionals, the term –
which refers to a cargo security initiative that took effect in January – has
yet to gain universal recognition. While many conference attendees had at least
a passing familiarity with the term, there were plenty of others – particularly
those who deal largely with domestic shipping – who didn’t seem to have a clue.
The lack of awareness can’t be put down to a scarcity of information. A fair
amount has been written about 10+2, particularly by those who are involved with
it. Nonetheless, a surprisingly large number of supply chain practitioners
appear to be vague on the details. This, then, will be an attempt to explain
10+2 to those who are interested – to those of you who aren’t, now would be a
good time to flip the page.
Officially known as the Importer Security Filing (ISF) and Additional Carrier
Requirement, the 10+2 rule is intended to help the U.S. Bureau of Customs and
Border Protection (CBP) screen incoming ocean containers for security risks.
About 7 million containers are unloaded at U.S. ports each year, each offering a
potential opportunity for terrorists and smugglers to bring dangerous or banned
material into the country. CBP believes that by gathering information about
these imports before they arrive on U.S. shores, it will be better able to
target high-risk shipments for further inspection.
Under the rule, both importers and carriers must submit specific information
on the cargo prior to its arrival in the United States. Importers are
responsible for providing 10 data sets for each container; ocean carriers are
required to provide two additional sets – hence the name "10+2."
Importers must submit their date to CBP electronically 24 hours before a
container is loaded onto a ship bound for the United States (with two
exceptions, noted below). This is the ISF transmission and consists of:
Name and address of seller
Name and address of buyer
Importer of record number
Consignee number
Manufacturer or supplier
Ship-to party
Country of origin
Commodity Harmonized Tariff Schedule number
Container stuffing location*
Consolidator name and address*
*This information is not required before loading but must be provided no
later than 24 hours prior to the container’s arrival at the port.
Carriers are responsible for providing the last two data elements, which they
must do no later than 48 hours after the ship’s departure from the port of
origin. The elements are:
To further complicate matters, there is the issue of containers that remain
on board after cargo is discharged at a U.S. port. For this cargo, five data
elements must be transmitted 24 hours prior to loading. These are:
Booking party name and address
Ship-to party
Commodity Harmonized Tariff Schedule number
Foreign port of unloading
Place of delivery
Although importers and carriers have already developed methods of gathering
and transmitting data that ease the burden, it’s clear that complying with 10+2
is a cumbersome procedure. What’s not co clear is whether all that effort is
justified for an initiative whose effectiveness, I believe, is questionable.
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