cargo smart workshop - bpe 10+2 presentation 10.7.08

8/3/2019 Cargo Smart Workshop - BPE 10+2 Presentation 10.7.08

1/38

Beth Peterson, .

10+2 Customer Co-Design Workshop


2/38

Beth PetersonEnterprises, Inc.

Agenda

SAFE Port Act

10+2 the known, the pretty sure and the

unknown Trade Support Network efforts to date

Data collection

os o + Other import legislation to take note of

2008 by Beth Peterson Enterprises, Inc. Proprietary and Confidential


3/38


About BPE

Global trade consulting for import, export and security.

Online training courses.

Experience

Over 21 years in global logistics, supply chain and.

Service Provider, licensed customs broker.

Industry, US import operations.

ec no ogy, pro uc s ra egy an mar e ng. Volunteer, government and trade association.



4/38


About You

.

Customs and Trade Partnership Against TerrorismC-TPAT .

Importer Self Assessment (ISA).

10+2.



5/38

Beth Peterson, .

SAFE Port Act


6/38


October 2006 SAFE Port Act

Authorization to expand the Container Security Initiative(CSI).

Strengthen physical security measures at US ports through theuse of technology.

Establishes container minimum security requirements. o ca on o - .

Requires CBP to utilize 3rd Party C-TPAT Validators.

Opens C-TPAT up to multiple parties (e.g. 3PLs).

Transportation Worker Identification Credential (TWIC) Requires the development of a trade resumption plan.

Re uires 100% car o scannin .

Improves the Automated Targeting System (ATS) = 10+2.



7/38

Beth Peterson, .

Importer Security Filing


8/38


Its Really Not 10+2

mpor er equ remen s

10 Data Elements

1. Manufacturer name and address

arr er equ remen s

2 Data Sets1. Vessel stow plan

. e er name an a ress

3. Container stuffing location

4. Consolidator (stuffer) name andaddress

.

Bill of Lading

Filer Code

Filing Number

Bond

5. Buyer name and address

6. Ship to name and address

7. Importer of record number

8. Consignee number

9. Country of origin of goods

10. Commodity HTS number (6 digit)



9/38


How is the ISF Different Than a Customs Entry?

Importer Requirements10 Data Elements

1. Manufacturer name and address Manufacturer info is often not known and is

2. Seller name and address

3. Container stuffing location

4. Consolidator (stuffer) name and

v ewe as con en a y se er

Available in a typical P.O.

Not recorded in current entry documents

address

5. Buyer name and address

6. Ship to name and address

Available in a typical P.O.

Could vary depending on the transaction type(e.g. FOB vs. DDP)

. Importer of record number8. Consignee number

9. Country of origin of goods

Manufacturer information, product genealogyis often difficult to trace accurately

Often missing or incorrect w hen P .O.s arewritten; t icall manuall corrected b

. ommo ty num er Broker at the time of entry filing



10/38


ISF Realities

.

Importer of Record is responsible for filing. Can appoint agent (such as customs broker) to perform filing

on its behalf.

CBP will not regulate who is authorized.

Not all service providers plan on offering filing service.

Data elements will be filed through ABI or AMS,and eventually ACE.

merchandise.

Suret bond re uired for the ISF.



11/38


CBP Prototype - ATDI

Focus is on natural aggregation points to leverage in-place business models and require minimal systemprogramm ng.

No special data format required.

CBP is simply an additional recipient for data alreadybeing passed among parties (minimize burden).

Data can be provided post departure



12/38


CBP Prototype Secure Freight Initiative

.

Majority are providing data post lading or postde arture and data is from multi le sources.

Many are large companies who have and IT

department and funds to support participation. Data is a one-way feed to CBP.

Data provider does not receive any messages from.



13/38


Hot off the Press



14/38

Beth Peterson, .

10+2 The Known, The Pretty Sure and The


15/38


The Known

.

RO/RO and Break-Bulk are exempted from atimin ers ective.

Bulk is exempted.

There are several importers IE, TE = 7512 Filer

FTZ = 214 Filer

Customs entr = Im orter

IT = Importer

Amendments are required up until arrival.



16/38


The Known

.

There will be an ISF confirmation.

message.

ACE M1 will include 10+2. File at the lowest B/L level (Master or House).

Phased in enforcements.

ransac on se s are a : http://www.cbp.gov/xp/cgov/trade/automated/automat

ed_systems/sf_transaction_sets/



17/38


Pretty Sure Of

.

60-90 day implementation period.

ID.



18/38


The Unknown

.

What the cut-off for amendments will be.

.

If there will be any account level processing.

What the enforcement phase in period will be.



19/38


The Unknown

that have been submitted. CBP ma be lookin at issuin Do not Load

messages for ISF.



20/38

Beth Peterson, .

Trade Support Network Efforts to Date


21/38


TSN Activities

,

consensus of trade committee representativeswas submitted to CBP.

July 22, 2008: Questions on technical datarequirements published by CBP were created and

representatives. CBP requested that discussionnotes were not published.

August 2008 Committee technical dataquestions were discussed by the COAC and



22/38


TSN Commitment

implementation of the ISF. To communicate as clearl and often as ossible

regarding the technical requirements.

To represent all members of the tradeu y.



23/38

Beth Peterson, .

Data Collection


24/38


A Cross-Functional Approach

Gathering Dataat Origin

Organizing DataCentrally

Filing and ManagingAdjustments

Supplier contact

Collecting, validating

Leverage technology

Multiple origin 3PLs

Connecting the dots

Process: timing of

Trust - Broker

Under bond

Leverage security filing,

Broker



25/38


What Shipments Will Be Issues

.

Prototypes and R&D materials.

.

Manifest discrepancy (incorrect goods).

Trade shows. Vendor managed inventory shipments.

Shipment ownership transferred in transit.

Supplier consolidation shipments (multiplesuppliers, single manufacturer).



26/38

Beth Peterson, .

Cost of 10+2


27/38


Potential Costs of 10+2

No load messages. Non-compliance = no unloading at destination.

Additional inspections.

Carrier schedule and capacity issues.

involved.

Extra inventory.

.

Costs of rerouting shipments, including shipments thatnow transit the U.S.

rem um re g c arges.



28/38


Potential Costs of 10+2

Predicted waiting time charges at container yards(estimated at $40 per hour per container).

Costs to secure containerized cargo.

Collection fees.

Filin fees.

U.S. Customs bond.

Connection charges, etc.



29/38


Calculating Inventory Carrying Cost

Purdue University: Each extra day adds 0.8% ad valorem to the cost of

goods.

Each additional day in ocean transit reduces the

probability that a country will export to the U.S. by 1%for all goods and 1.5% for manufactured goods.

Adding a single day to transit can only be offset

planning.



30/38


Other Factors to Consider

the additional transaction volume? Carriers ma not want to become stora e

facilities, may require proof of filing prior toacceptance of freight.

r w ur y r y r y rthe opportunity for containers to be tampered withwhile sitting for an additional days.



31/38


Bond Requirements

prior to entry. Liabilit attaches based on conditions that are

beyond the importers control.

Affords CBP a general license to imposeu r v rinfractions.

It bestows u on CBP officials virtuall unfettered

discretion because the ability to penalizeimporters.



32/38

Beth Peterson, .

Other Items to Take Note Of

B th P t


33/38


Worldwide Security Programs

Country Program Name

WCO SAFE Framework of Standards (SAFE)US Customs Trade Partnership Against Terrorism (C-TPAT)

CA Modernized Partners in Protection (PIP)

JP Authorized Ecnomic Operator (AEO)

NZ Secure Exports Scheme

SG Secure Trade Partnership (STP)

EU (27) Authorized Ecnomic Operator (AEO)

Jordan Golden ListMX Alliance for Secure Commerce


B th P t


34/38


Lacey Act (16 USC 3371)

ew mpor ec ara on or p an s an p an pro uc s.

1. Genus and species of any plant contained within the shipment,2. Plant species country of origin (i.e., the country where the plant

was arves e , cu , ogge , or remove

3. Value of the importation and quantity (including the unit ofmeasure) of the plant/plant product.

,trees, roots, seeds, parts, and products constructed thereof.

May potentially include all wood and

furniture, textile and apparel productsof rayon, paper products, and many

plant components.



35/38

Beth Peterson, .

Closing

Beth Peterson


36/38


Final Thoughts

a real prototype that covers the full range ofcompanies involved in the supply chain.

na u e s w now you s ave me olet Congress know how this will impact you:

Cost Prototype

Bond

Penalties

Etc


Beth Peterson


37/38


BPE Website for You!

. .

User id: Cargosmart Password: 10+2n0w



38/38

Beth Peterson, .

Questions/Comments?

cargo smart workshop - bpe 10+2 presentation 10.7.08

Documents