If you are a U.S. importer of goods that are entering the U.S. by ocean vessel, then you need to be concerned with the complete, accurate and timely submission of Importer Security Filing (ISF) information with U.S. Customs and Border Protection (CBP).  With the "Importer Security Filing and Additional Carrier Requirements" interim final rule having gone into effect on January 26, 2009, now is the time to assure your Importer Security Filing (ISF) responsibility can be fully met.

The current 12-month time frame when the interim rule is in effect is termed the "structured review and flexible enforcement period" by CBP.  This flexible enforcement period ends on January 26, 2010.  Federal law requires that importers must comply with the ISF requirements on and after January 26, 2010.  

CBP has stated that they will not assess liquidated damages nor issue any do not load (DNL) messages solely based non-compliance with the new ISF requirements during the structured review and flexible enforcement period.  However, CBP reserves the right to take enforcement action, including the use of the DNL option, to help assure the goods entering the U.S. do not pose a security risk or safety concern.  And perhaps more importantly, CBP does take into account the importers progress in the implementation of meeting the ISF requirements as a mitigating factor in any enforcement action incurred after the final ruling goes into effect.

The good news is that CORTEZ is ready to be your ISF Agent, whether you are already importing ocean goods with us or are looking for an improved service provider.  Importers currently filing entries with us are already setup in our ISF Portal and we are ready to file ISFs on their behalf.  And, we anticipate that unified customs entry and ISF filing will be ready for production soon, providing your company an even more efficient way to assure U.S. Customs compliance with your imports.  Importers new to our services only need provide a signed Power of Attorney (POA) to get started.

Please call or email your favorite CORTEZ contact today to see how we can solve your business process need of making sure your ocean imports are compliant with the new ISF rule.  And remember, CBP will only show some constraint in enforcing the ISF rule for importers "so long as importers are making satisfactory progress toward compliance and are making a good faith effort to comply with the rule to the extent of their current ability."  This CBP statement and other pertinent ISF information can be found on CBP's  "Importer Security Filing "10+2" Program FAQs" document.