CBP has not yet finalized the 10+2 rule and companies will likely have a year to implement the rule once it is finalized.
This doesn’t mean you can’t (or shouldn’t) do anything now. In fact, there are many steps you can take now that will ensure that you are prepared when the ruling is finalized and may even give you a leg up over less-prepared competitors. Most of the key elements of the rule are already well-established, so there is no sense in waiting to do the things that can be already be done.
Here are three steps you can and should take right now:
First, read the Notice of Proposed Rule Making from CBP, which you can find here.
Second, conduct a self assessment of the availability of your supply chain data. Look at the elements you will have to provide, look at what you have available, and start to figure out how to bridge the gap between the two. Remember, there may be significant lead time in creating the links you need to your external sources of data.
Third, evaluate your current and potential partners and vendors and ensure that they are taking the steps they will need to take to help you comply.
The 10+2 rule will have a significant impact on every importer in the United States. It pays to be prepared for such regulatory earthquakes to the extent that you can be. And, in fact, preparation may even have its own benefits.