Importer Security Filing
On January 26, 2010 You MUST File a 10+2 or Face Penalties!
U.S. Customs and Border Protection is serious. On January 26, 2010 they will start issuing penalties for failure to comply with the Importer Security Filing (ISF), also known as the 10+2. We can file for you or your shipper overseas can do it, but someone must. Failure to file will result in a $5,000 per violation penalty. You can also be fined for filing incomplete or wrong information. Therefore, the total penalty per shipment could be as much as $10,000.00.
Customs' regulations require that this information be filed 24 hours prior to the loading of the vessel. In order for us to accomplish this, we need to receive the documents 4 days before departure of the vessel. This will give us ample time to file and save you from facing a penalty. If there are any corrections we will need that information immediately so we can update the information with Customs. I cannot state enough that this is YOUR responsibility and YOUR penalty.
U.S. Customs is also requiring an additional bond for the ISF. This can be done with a single ISF bond, which will carry an additional charge. The shipment and ISF can also be bonded with a continuous transaction bond.
Arizona Customs Brokers is here to assist you with this filing and the bond. On our website, arizonacustomsbrokers.com, you can download "The Importer Security Filing Data Sheet", found under forms. We have setup a special email address for you or your overseas partner to send the form and documents. This address is email@example.com. If you have any questions regarding the ISF or bonding requirements please give Robert Hornyan a call at 602-273-0912. We are here to assist you and keep you penalty free.
Imported Composite Wood Products Must be TSCA Compliant as of March 2019
Thursday, December 13, 2018
Sandler, Travis and Rosenberg Trade Report
A December 2016 final rule from the Environmental Protection Agency established national formaldehyde emission standards and a third-party certification system for regulated composite wood products (i.e., panels), including hardwood plywood, particleboard, and medium-density fiberboard, to ensure those panels are compliant before being sold to end users or fabricated into component parts or finished goods (furniture, cabinets, picture frames, toys, etc.). Between June 1, 2018, and March 22, 2019, such goods that are imported into or manufactured in the U.S. must be (a) certified as compliant with either Title VI of the Toxic Substances Control Act or the California Air Resources Board's Airborne Toxic Control Measures Phase II emission standards by a third-party certifier approved by CARB and recognized by EPA and (b) labeled as compliant with the relevant standard.
U.S. Customs and Border Protection is now advising interested parties that after March 22, 2019, such goods may only be certified and labeled as compliant with TSCA Title VI- labeling them as compliant with the CARB ATCM Phase II standards will not be sufficient.
Also beginning on that date importers will be responsible for providing a TSCA Section 13 import certification for articles containing regulated composite wood products, component parts, or finished goods imported into the U.S. customs territory. This import certification will be in the form of a positive certification for applicable shipments through the Automated Commercial Environment. CBP adds that upon request from the EPA importers must make available within 30 calendar days certain records that document compliance.
Additionally, the EPA recently published a proposed rule that would, among other things, clarify that regulated composite wood products and finished goods containing such must be labeled at the point of manufacture or fabrication. If the product is imported, the label would have to be affixed to the product by the date of importation.
2019 Federal Holidays
For your information, below is a listing of Federal Holidays for Calendar Year 2019. These dates can also be found at:
Date - Holiday
Tuesday, January - 1 New Year's Day
Monday, January 21 - Birthday of Martin Luther King, Jr.
Monday, February 18 - Washington's Birthday
Monday, May 27 - Memorial Day
Thursday, July 4 - Independence Day
Monday, September 2 - Labor Day
Monday, October 14 - Columbus Day
Monday, November 11 - Veterans Day
Thursday, November 28 - Thanksgiving Day
Wednesday, December 25 - Christmas Day
Imported Plywood Products Could be Hit With Significant AD/CV Duties
Thursday, January 24, 2019
Sandler, Travis and Rosenberg Trade Report
Goods made with hardwood plywood and imported from China may be hit with antidumping and countervailing duties as a result of increased scrutiny by U.S. Customs and Border Protection.
The AD and CV duty orders on hardwood plywood products from China went into effect Jan. 4, 2018. The goods subject to these orders are hardwood and decorative plywood and certain veneered panels. All hardwood plywood is included within the scope of these orders regardless of (1) whether or not the face and/or back veneers are surface coated or covered, (2) whether or not such surface coatings or covers obscure the grain, textures, or markings of the wood, (3) whether the plywood is trimmed, cut-to-size, notched, punched, or drilled or has undergone other forms of minor processing, (4) dimension, and (5) further processing in a third country.
According to Kristen Smith, who heads Sandler, Travis and Rosenberg's Trade Remedies Practices, the International Trade Administration is now holding that some cabinet and furniture products made of hardwood plywood that were previously considered excluded from the scope of these orders are in fact covered if they are not imported in a single box. As a result, importers of such goods face significant duty liability, with current AD duty rates at 171.55 percent to 183.36 percent and CV duty rates at 22.98 percent to 194.90 percent.
Affected companies have until Feb. 28 to request administrative reviews of these orders in an effort to lower these duty rates. It is unlikely this deadline will be extended despite the ongoing federal government shutdown, Smith says.
Attention Ocean Importers
Beginning January 26, 2009 all shipments destined for the United States must comply with the submission of "Importer Security Filing 10+2(ISF)". The importer is ultimately responsible for the data to be entered in the Import Security Filing even if entered by an agent of theirs. This data must be received by U.S. Customs 24 hours prior to the loading of a vessel. That data has to be reviewed, classified, processed and accepted in order for your shipment to be loaded on a vessel that is destined for the USA. This data has to be sent to U.S. Customs and Border Protection via an approved electronic data interchange systems.
Arizona Customs Brokers can do this for you.
Simply stated, the ISF requires the importer or their agents to provide ten data elements 24 hours before the departure of the vessel and the two remaining elements 24 hours before the vessel's arrival.
The original ten elements required are:
1. Manufacturer(Supplier)- Name and Address
2. Seller(Shipper)- Name and Address
3. Buyer(Purchaser)- Name and Address
4. Ship to Consignee or Ultimate Consignee - Name and Address
5. Container stuffing location - Name and Address
6. Consolidator(Stuffer)(Forwarder) - Name and Address
7. Importer of Record - ID Number
8. Consignee - ID Number
9. Country of Origin
10. Harmonized Tariff Schedule Number
Plus the last two elements:
1. Master Bill of Lading - House Bill of Lading(NVOCC)
2. Ocean Bill of Lading (if straight B/L).
Arizona Customs Brokers will be prepared to submit this information to U.S. Customs on your behalf. In order for us to comply with this regulation we will require that this information be sent to us 4 days prior to the delivery of the container to the port. We would also like the commercial invoice and packing list at this time. This will require additional work on our behalf and we will have to charge for this service. At this time we are not sure what the charge will be as things are still being worked out and subject to change.
Between January 26, 2009 and January 26, 2010 U.S. Customs will be evaluating any compliance difficulties. Customs reserves the right to take enforcement action when an importer is not achieving "satisfactory progress" or making a "good faith effort to comply" during this time. Customs penalties for non-compliance are $5,000.00 per violation.
Please call us with any questions you may have at 602-273-0912. As we get more information we will pass that along to you or you can check our website at www.arizonacustomsbrokers.com.
It is important that business partners and importers understand the importance of container security.
High security seals must be affixed to all loaded import containers bound to the U.S. These seals must meet or exceed the current ISO-PAS 17712 standards for high security seals.
We have provided a link to the Customs and Border Protection website for more information on this subject. If you have any questions concerning container security please give us a call at 602-273-0912.
CBP has a short video on container security which you can use as a training video.