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You’re right. Trade show exhibitors face new federal regulations when importing cargo via ocean liner from overseas. On Jan. 26, 2009, the Import Security Filing (ISF) rule, also known as the 10+2 rule, took effect. The 10+2 rule is one of many enhanced security measures implemented by the Department of Homeland Security following the 9/11 terrorist attacks on the United States. International exhibitors who fail to follow the new rule may be putting their next show in jeopardy, as the U.S. Customs and Border Protection (CBP) can not only fine exhibitors $5,000 per violation, but officials also can refuse to allow the cargo to be loaded at the point of origin until the proper information is received, thereby delaying the shipment.

Luckily for everyone, however, the new rule comes with a grace period. Because the regulations are complicated, the CBP has established a 12-month flexible-enforcement period. During this time, the CBP will refrain from issuing most fines as long as the importers show a good-faith effort to learn and thoroughly understand the rule and provide complete compliance in the future.

Despite the grace period, now is the time to familiarize yourself with the new rule — and to make sure all of your transportation providers, customs brokers, etc. are equally aware of it — so you can plan your compliance and sidestep any potential potholes in your path. Here’s the least you need to know about the 10+2 rule.

Under the rule, importers (in this case importers are exhibitors who are returning their shipments to the United States from overseas) are required to submit 10 pieces of information about their cargo at least 24 hours before it is loaded aboard a vessel at a foreign port. Two additional pieces of information are required by the carrier as well, hence the name 10+2. The 10 pieces of information must be provided for each item of exhibitry or material shipped back into the United States, such as exhibit components, literature stands, giveaways, light fixtures, etc.

The 10 pieces of data are:

1. Manufacturer (or supplier if applicable) name and address

2. Seller (or distributor if applicable) name and address

3. Buyer name and address (In the case of a U.S. return shipment from an overseas trade show, the U.S. exhibitor is both the seller and the buyer. So provide the same company name and address information for items No. 2 and No. 3.)

4. Ship-to name and address

5. Container-stuffing location (This is where the shipping container was loaded. For full-container loads, this is usually the international exhibition center, and for less-than-container loads, it’s usually the location at which the contents are consolidated and placed into the container.)

6. Consolidator name and address

7. Importer of record number

8. Consignee number (The consignee, also referred to as the U.S. Importer of Record, is the company that owns the merchandise. So when exhibiting internationally, the U.S. exhibitor is probably the consignee.)

9. Country of origin of goods

10. Harmonized Tariff Schedule of the United States (HTSUS) number (This number can be obtained by the exhibitor’s international freight forwarder or customs broker.)

In addition, the carrier must supply these two pieces of information:

1. A vessel-stow plan (This indicates the location on the ship where the container is placed for transport.)

2. Container status messages (Status messages include important data such as the container number, the date and time that the container was received and loaded, estimated time of delivery, estimated time of arrival, and other relevant events that may occur while the container is in the carrier’s possession.)

These 12 bits of data are entered into a proprietary software system that interfaces with the CBP’s electronic-processing system, the Automated Commercial System (ACS).

So while any party may provide the CBP with the data, that party must have access to the software system as well as the authority to use it.

Thus, it’s best to hire a U.S. Customs’ licensed broker to help you comply with the new rule, as brokers have access to the necessary data and are able to prepare and file both your customs-entry forms as well as the new ISF data. Plus, it only costs roughly $25 to $65 per shipment for a customs broker to input the ISF data, which is a pittance compared to the amount of time and energy it would take you to purchase the U.S. Customs’ software and receive CBP approval to transmit the ISF data.

Of course, as with almost all other shipping-related suppliers, make sure your customs brokers have trade show experience to ensure your data and forms are in compliance with all U.S. Customs regulations while also meeting the needs specific to the exhibiting industry. In terms of timing, customs brokers usually input the ISF information upon receipt. However, it’s a good idea to provide your customs broker with data no later than 48 hours prior to vessel loading.

Again, shipments processed through the end of the year fall in the flexible-enforcement period, so customs officials will likely grant you some leniency depending on the severity of your errors and your attempts to fix them. But rather than risking an exhibit held hostage, make sure everyone on your shipping team is aware of the new rules and how to work within them.

 

Phil Hobson, president, Phoenix International Business Logistics Inc.

1201 Corbin St. Elizabeth, NJ 07201

Ph:  908-355-8900

e-mail:  phobson@phoenixlogistics.com 

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