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Update on ISF Procedures
2010-02-23
Four weeks have passed since the Importer Security Filing (ISF) came into force on January 26th. Milgram, our agents and service providers are actively engaged in compliance with the requirements of ISF. Post-January 26, 2010 we are now in a brief phase of flexible and progressive enforcement. How is that significant?
- Do Not Loads (DNL's: orders from CBP that prohibit the loading of non-compliant containers) and other similar measures have been deferred until the second and third quarters (Q2 and Q3) of this year.
- CBP has delayed the imposition of liquidated damages (fines) until Q3 and Q4 of 2010; non-compliant importers will receive warning letters instead.
That does not mean that we can all relax. Now is the time to be proactive, making sure that our partners are providing the necessary information in the required fashion, in a timely manner.
- While DNL's for ISF have been postponed, that does not mean that non-compliant consignments will not be subjected to costly CBP exams and resulting delays.
- Late filing of ISF-10 may in fact precipitate liquidated damages.
- CBP will continue collecting information on accuracy and timeliness of the ISF data that is provided to them. "Report cards" are kept for each individual filer.
- Report card grades will be considered by CBP when it comes to mitigation of liquidated damages (that relates to quality, accuracy and timeliness of their ISF filing history) as was mentioned in a previous bulletin from Milgram.
- Those "grades" are one of several factors that determine risk assessment scores for import traffic (ISF, AMS history, indicators such as membership in C-TPAT).
Whether or not clients are using Milgram for their ISF-10 filings, it is important to maintain consistency and accuracy of the information that is provided for transmission by the filer. For those not using Milgram for ISF-10, in order to avoid fines for late filing, holds or DNL's when those come into play, it is incumbent upon you and your ISF provider to ensure that your reports are filed both accurately and on time.
Click here to obtain an updated version of CBP's slideshow presentation on ISF and here to obtain Updated ISF FAQ's.
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