Well, maybe.  But there is now a (pretty brief) Wikipedia entry.  Next stop:  YouTube.

There were a lot of questions asked at the recent 10+2 webinar, more than could be answered in the time allotted.  Our friend Beth Peterson took the time to answer all of them.  Here are the first twenty:

ACE

At some point will the ISF data be available on ACE?

• The ISF data is not available in ACE at this time. It will be quite some time until ACE includes ISF data according to Lou Samenfink of CBP.

AMENDMENTS

Can you help us out with the timing of making amendments and by when must filers submit the updated data?

• CBP has not specified how quickly the amendments must be made other than stating that amendments should be filed when the changed or more accurate data becomes available. The Importer Security Filing must be amended if there is a change or more accurate information becomes available before the goods enter the limits of a port in the United States. For goods that will be unladen in the United States, the Importer Security Filing must be updated if there is a change before the goods enter the port of discharge.

Amend ISF for quantity? Why?

• Beth misspoke, quantity is not required for ISF’s.

AMS

Are you filing your ISF prior to AMS filing?

• For vessel carriers, that are not bulk or approved break-bulk, CBP must receive from the carrier the cargo declaration information in AMS 24 hours prior to the lading of cargo on the vessels, and for automated NVOCCs, the cargo declaration information merely needs to be transmitted 24-hours prior to lading of cargo. ISF is also required 24 hours prior to lading of the cargo but we’re anticipating that carriers will require the information even earlier.

BILLS OF LADING

When Customs implemented 10+2, I don’t recall anyone mentioning that a House or Master Bill of Lading would be needed to track the shipments. I’m assuming this is needed so Customs can tie the information together. Why wasn’t more emphasis placed on this? This really isn’t 10+2, it should be called 11+2….Is this information necessary?

• You are correct that the bill of lading is needed to identify the shipments and to tie the ISF filing to the carrier status messages and stow plan. In addition to the bill of lading, you are also required to submit a filer code and a bond type so its really 13-2.

What ties the importer’s 10 data elements to the carrier’s 2 data elements?

• The lowest level House or Master bill of lading.

Can you recommend the best way to coordinate or time the filing with the bill of lading submission from the carrier? I’m hearing that importers are finding it difficult to get their BOL from their ocean carrier early enough so they can file the ISF in a timely fashion. How are the carriers responding to this situation?

• We’re hearing this too. According to CBP “The ISF Importer must obtain the bill of lading number. The bill of lading number is an integral part of the security filing. Without the bill of lading number, the ISF cannot be matched to a customs manifest.“ You are going to have to work with your carriers to get these numbers up front. You cannot use a “dummy” number and then replace it with the correct bill of lading number because the bill of lading number is the ISF identifier. You would have to submit a new ISF if you have a different number and this would probably be considered a late filing.

(from the audience) Carriers are using booking numbers to convert to Bill of Lading numbers to make them available. This should become a standard.

At what event is the B/L number created by the carrier?

• It varies by carrier. You should work closely with your carrier to ensure that they are assigning the bill of lading number early enough for you to file the ISF 24 hours in advance of lading the goods on board the vessel at the foreign port of lading.

Currently we were given advice to put “any number” in the Bill of Lading Number field that does not exceed 10 digits of course. When we receive our BL # then we can issue an amendment. 1) Are they capturing this issue in the 15% failure rate, and 2) Do you see this showing up on the report card, 3) This would clearly be a violation after 1/26/10? Finally, how are the carriers doing on compliance?

• You cannot amend the bill of lading number on and ISF. You will be required to cancel the ISF with the incorrect number and resubmit. However you risk filing your ISF late in this case.

• We do not believe that incorrect bill of lading numbers are resulting in ISF failures.

• The report card includes a “Frequency of ISF-10 Filings by Number of Days Leading/Lagging Bill Filing Date” – but it’s not clear what this is actually measuring.

Can you use your booking number as your BOL number for ISF?

• Yes, if the booking number is the same as the bill of lading number.

I’m confused about filing multiple b/l’s per ISF. Does this mean I can have multiple parties per ISF. Example if I have one b/l can I have multiple sellers and buyers. If I have multiple b/l’s can I have multiple buyers and sellers also?

• A single ISF may cover multiple bills of lading as long as they are all going to the same importer as part of the same shipment on the same vessel voyage.

For an importer that uses NVOs, is B/L concern the House or Master B/L?

• It’s the lowest level bill of lading available.

BONDS
Does the shipper need a bond if their broker is filing as their Designated ISF10 filer?

• CBP is postponing the requirement for bonds until January 26, 2010. At that time, the ISF filer may use the importer’s continuous bond or their agent’s bond. It’s important to determine who’s bond will be obligated as part of your Standard Operating Procedures and if you do utilize your agent’s bond, you will want to understand the costs to do so.

Is there an additional bond required to what is already in place?

• Not at this time. It isn’t very clear how CBP intends to implement the bond requirements and you should stay in touch with your surety company while this is being further defined.

Is a separate bond required to file the ISF?

• No, CBP is postponing the requirement for bonds until January 26, 2010. At that time, the ISF filer may use the importer’s continuous bond or their agent’s bond.

BULK
What if I ship bulk and my shipment ends up in a container with other shippers….if they are delayed due to ISF issues…will that delay my shipment too?

• You are required to submit an ISF if your bulk goods are placed in a container. If your container includes other LCL importers, your goods could be held up due to items being imported by other parties included in the container that your goods are shipping in.

Is this statement correct for break bulk? If the carrier you are using had applied for and received a break bulk exemption from the timing requirement for cargo declaration under 19CFR 4.7(b)(4)(ii), for ISF you can get an exemption from the 24 hour rule before lading and you can file the ISF 24 hrs before arrival in the USA. If the carrier does not already have the exemption in place you must file 24 hours before the vessel is loaded at the point of export.

• Yes, break bulk has a timing exception – you can file your ISF for break bulk 24 hours in advance of arrival of the merchandise.

BUYER

For the “first sale” rule, does CBP want to see the “first sale” buyer (middle man) or the end buyer (consignee)?

• It would be the buyer at the time of the ISF filing.   If the buyer changes during the sailing, an ISF amendment will need to be filed.

CARRIER STATUS MESSAGES
Are status messages being sent for all ISF filings?

• Carrier status messages are required to be filed for every ISF. The carriers are subject to penalties if they fail to file status messages.

CBP Representative
How do we contact a CBP rep in our specific New York area?

• We recommend that you start with your (or your broker’s) ABI/AMS representative, they have all be trained. Also, CBP has outreach events scheduled for March in New York.

We recorded it.  You can find it here.  I think people found it useful; give it a listen and decide for yourself.

There were over 100 questions asked; time limits prevented answering all of them during the course of the webinar, but I think we will try to get written answers to the rest and post them here.