Trade Compliance News

10 + 2 Enforcement Begins January 26, 2010

Mark your calendars! Full enforcement of the 10 + 2 Importer Security Filing (ISF) starts on January 26. On Tuesday, at the Trade Symposium, Acting Commissioner Ahern stated that the least punitive informed compliance mechanisms such as warning letters and increased inspections for ISF violations would be used in the beginning. CBP doesn’t want to hold the cargo hostage, and they don’t necessarily want your money – they want the data. Supply the data and you get the cargo. The clock is ticking and the trade has had a year to prepare for the full implementation. It can take anywhere from 30 to 60 days to initiate the changes necessary to produce the required information, so if you haven’t started or are not actively participating, don’t delay.


New: Import Safety Commercial Targeting and Analysis Center (CTAC)

The CTAC is a new CBP facility designed to streamline and enhance federal efforts to address import safety issues. In addition to the focus on preventing terrorism and crime, another goal is to protect our citizens from unsafe products. With the increased incidents of lead based paint in toys and tainted food found in imports from China and other countries, safety of imported goods has become more important. The CTAC will be staffed by approximately 30 employees from the various participating agencies, including CBP, ICE, FDA, FSIS and CPSC.


Annual Report for Counterfeit Goods Seizures Published

Last week, U.S. Customs and Border Protection and U.S. Immigration and Customs Enforcement announced that in fiscal year 2009 they made 14,841 seizures of counterfeit and pirated goods with a total domestic value of $260.7 million. Goods from China accounted for the largest amount seized by country and footwear was the top commodity seized. Not only does the importation of counterfeit goods cause economic harm, but these goods also pose safety concerns. Three of the top ten categories of commodities seized also posed possible safety or security risks. Check out the report and various statistics online.


BIS Proposes Elimination of Most Paper Documents

On December 4, 2009, the Federal Register published a proposal by the BIS to eliminate the use of most paper documents sent to parties doing business with the agency. The documents affected by the proposed rule include:

· Export and Reexport Licenses
· Notices of denial of License Applications
· Notices of Return of a License Application without Action
· Classification Results
· License Exception AGR Notification Results
· Encryption Review Request Results.

The proposed rule would require modifications to the EAR and make changes to the recordkeeping requirements. Comments on the proposal must be received by BIS no later than February 2, 2010.