10+2: Origin and Destination in Collaboration
The clock is ticking for importers struggling to become compliant with Customs and Border Protection’s (CBP) Importer Security Filing regulation, commonly known as the 10+2 initiative. On Jan. 26, 2010, the interim final rule becomes mandatory, allowing CBP to begin assessing damages for failure to meet the new data-filing requirements.
The key to successful 10+2 filing is establishing collaboration among players at both origin and destination, instead of placing the onus on customs brokers, who are often ill-equipped to collect some of the crucial, time-sensitive data that is only available at origin.
TIMING IS EVERYTHING
The data fields required for 10+2 include static, unchanging data, and dynamic data that is shipment-specific and/or collected very close to the lading time, such as the bill of lading number and the container stuffing location data. Creating a collaborative environment between origin (the shipper or exporter) and destination (the customs broker or importer) helps alleviate the timing issue of getting dynamic data to CBP 24 hours before lading.
One way to achieve this collaboration is by using an Internet-based 10+2 system where dynamic data is inputted at origin as it is generated. This type of resource allows supply chain partners in different time zones to enter and access data during their own business hours.
TIME ZONE DIFFERENCES
According to regulations, the 10 elements to be provided by the shipper must be filed no more than 24 hours before containers load on board the vessel—known as the container yard (CY) cutoff. Most shipping vessels sail on the weekend, and approximately 65 percent of all automated manifest system data is input during the Asian workday each Friday—or 6 p.m. Pacific Standard Time (PST) Thursday evening through midnight. Administrative corrections are made in the last two hours before CY cutoff—1 a.m. to 8 a.m. PST Friday morning.
U.S. brokers without a local presence at foreign ports are forced to work through the night on Thursday to bring all 10+2 data into their systems in order to file with CBP before the deadline. To complicate matters, brokers attempting to contact a shipper directly must contend with time zone and language challenges. Brokers in the United States could arrange to call late Thursday night while 10+2 data is becoming available during the Asian workday on Friday, but unless they can communicate clearly, getting all necessary information to file properly could be a challenge.
A 10+2 filing system must address Hold messages from CBP in real time, during the Asian/European workday, for example. Thus, a robust 10+2 solution includes a feedback loop to origin. A particularly good 10+2 option for a customs broker includes employing a support staff member at origin who can address Hold messages without forcing the broker to work through the night.
The most effective 10+2 solution involves the shipper or exporter in the reporting process and includes a local presence at origin to contact shippers directly if necessary. It creates a fully visible supply chain from the moment the container is stuffed—and a particularly robust system begins that process the moment a purchase order is filed. With this type of system in place for 10+2 compliance, the entire supply chain becomes far more visible, more efficient, and safer.