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The ABC’s of Customs Brokerage

ABCCB1000

Week 5 Student Guide

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Assignment Checklist By following this checklist, you will be able to complete the course assignments during the week. Be sure you read the directions for each of the assignments and discussion forums provided in the guide starting after this checklist. Read / Watch: Watch Week 5 Introduction Video

Watch the ISF Video Review CBP Form 214 Read CBP 2018 ISF FAQ Review the ATA Carnet sample

Discuss: ⇔ Why Continuing our Education is Important

⇔ Determining Entry Types ⇔ Why Cargo Security is Important ⇔ The benefits of using a Carnet

Submit your initial post to discussion forums by day four of the week, midnight (Eastern Time). Your initial post should be between 200-300 words. Replies to fellow classmates should be no less than 50 words.

Submit: ⇔ Essay: What I’ve Learned and How it will Help Me ⇔ What Entry Type and Why (5.1) Assignment ⇔ ISF Advise Sheet (5.2a) ⇔ Quiz

Submit your assignments as an attachment by the last day of the week, midnight (Eastern Time).

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Week Five Quotes

“The only real measure of the effectiveness of teaching is what happens in the mind

of the person learning.” ~ Erika Andersen

“Few things are as potentially difficult, frustrating, or frightening as genuine learning, yet nothing is so rewarding and empowering.”

~ Adam Robinson “Each day presents an opportunity to learn more, do more, be more, grow more.”

~ Reid Hoffman “Keep learning, because the world keeps changing. You have to go to bed wiser

than you got up. With this approach, you are sure to rise.” ~ Charlie Munger

Because we cannot advance without learning, I’ve chosen several quotes for Week 5 to help us focus on, well, learning. Before we start this week’s lesson, let’s take a moment to reflect on what we’ve learned and why continual education is important. Post in the discussion forum titled Quotes and be sure to discuss why we must never stop learning, growing, and educating ourselves. This week we will review some entry types and how to determine which entry type should be used for a specific transaction. Some entry types may be changed after submission and some may not. Week 5 – What I’ve Learned and How It Will Help Me Before we jump into the entry types, let’s reflect on what we’ve learned so far. Reflection is another way to recall. This is where I say, “The three R’s – reflect, recall, remember will help us grow.” We’ve covered quite a bit – from soft skills and customer service to actually filling out entry papers. We have much more to cover, but before we do please take a moment and submit an essay on “What I’ve learned and how it will help me”.

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⇔ Reflect, recall, and remember – write a short essay (200-300 words) about what you’ve learned and how it will help you. Then upload it.

Week 5 Lesson 1 – Determining Entry Types Some entry types are easy to determine while other may require some additional research. Some factors in determining the entry type will be value, HTS number, country of origin, and commodity specifics. Entries have a code number and a name. The code number is two digits. CBP distinguishes these codes (as noted in our 7501 instructions) with the first digit in general categories of 0= consumption; 1=informal; and 2=warehouse. The second digit identifies the specific processing type within the entry category. Included in your study material is a copy of the Customs Automated Manifest Interface Requirements Appendix D – Entry Type Codes (NOTE: This is from 2000, but still has valid entry type codes for review). Not all entry types are supported by ACE. A list can be found at the CBP site on the ACE Transaction Details page. Let’s review some of the most common entry types. Entry Type 01: This entry type is referred to as “formal entry” as well as “free and dutiable consumption entry”. This entry type can be used for shipments of any value, although generally used for shipments valued over $2500.00 unless restricted. Those restrictions would be, for example, if any item in the shipment was subject to quota, antidumping or countervailing duty, or subject to 9903 or 9904 additional HTS numbers. Entry Type 02: This entry type is referred to as “formal quota entry” as well as “quota/visa consumption entry”. This entry type is for merchandise valued over $2500.00 that is subject quota/visa and not subject to any antidumping or countervailing duties. Quota is used to regulate the amount of various commodities being imported into the US. There are primarily three types of import quotas administered by CBP: absolute quotas, tariff-rate quotas (TRQs), and tariff preference levels (TPLs).

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Absolute quotas permit a strictly limited quantity of specified merchandise to be entered or withdrawn from warehouse for consumption during specified periods. Once the quantity permitted under the quota is reached, no further entries or withdrawals for consumption of merchandise subject to that quota are permitted until the opening of the next quota period. If an absolute quota fills, the importer must warehouse, export, destroy, or abandon merchandise imported in excess of the restraint limit. Tariff-rate quotas permit a specified quantity of merchandise to be entered or withdrawn from warehouse for consumption at a reduced duty rate during a specific period. Quantities imported in excess of the quota can be entered in unlimited amounts during the quota period, but are subject to higher rates of duty. Many free trade agreements and other special trade legislation establish Tariff Preference Levels for certain textile and apparel products. CBP administers these restraints like tariff-rate quotas because they are similar. Just as with a TRQ, quantities imported in excess of the TPL limit are permitted in unlimited quantities at a higher rate of duty (the rate specified in column one of the HTSUS.) Additionally, merchandise in excess of the TPL limit or found not to be eligible for TPL benefits becomes subject to any duty or restrictions that may be in effect at the time for non-qualifying shipments. CBP has a Quota FAQs page as well as a Quota Enforcement and Administration page for more information on quota. CBP also has a page with Commodities Subject to Import Quotas. Other entry types that can be used in conjunction with quota merchandise are: Entry Type 07 – for commodities subject to AD/CVD and Quota/Visa regardless of value; entry type 12 – for commodities subject to quota only and valued under $2500.00; entry type 32 – for commodities subject to quota that have been entered under a warehouse entry type; entry type 38 – for commodities subject to AD/CVD and quota/visa that have been entered under a warehouse entry type. Most quotas are opened on January 2nd at 12:00 noon Eastern Time. This enables all ports, whether on the east coast, mid-west, or the west coast to submit quota entries at the same opening time. Some quotas, such as

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peanuts, open according to the season. Peanut quotas open on 4/1 and close on 3/31 the following year; raw sugar quotas open on 10/1 and close 9/30 the following year. NOTE: Some of the CBP pages read “there are currently no absolute quotas”, however there still may be as quotas can be issued under Presidential Proclamation and therefore are subject to change. It is important to be sure you review the “Last Modified” dates on the pages to ensure you are reviewing the most current information. The Commodity Status Report page is updated weekly and contains the current quota commodities and fill limits. Entry Type 03: This entry type is referred to as “antidumping or countervailing duty” entry or “consumption AD/CVD”. An entry type 03 is used if any item in a shipment is subject to AD/CVD regardless of value. If the item is valued at $1.00 and subject to AD/CVD an entry type 03 is required. So, what is antidumping and countervailing duty? Years back I had an employee who thought those duties had to be paid if the IOR was going to send the item to the dump. Let’s just say, that’s not what it means… Dumping occurs when a foreign producer sells a product in the United States at a price that is below that producer's sales price in its home market, or at a price that is lower than its cost of production. Countervailing duty is imposed because of subsidization. Subsidization occurs when a government provides countervailable financial assistance to benefit the production, manufacture, or exportation of a good. When an antidumping or countervailing duty order is imposed, Commerce instructs CBP to assess antidumping and/or countervailing duties on imports of the product into the United States to offset the unfair trade practice. You may recall from Week 3, there are three agencies that play a role in the administering and collection of AD/CV duties – The Department of Commerce, the International Trade Commission, and CBP. The Antidumping Act was passed in 1921 and has the Sherman Act (anti-trust) provisions to thank. AD/CVD orders are tied to the HTS number, but are distinguished by the “scope” of the item. AD/CVD orders are also tied to a specific country.

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For example, wooden bedroom furniture from China, which could be classified at 9405.50.9040, 9403.50.9080, 9405.50.9040, or 7009.92.5000, is subject to antidumping. Yes, there is a classification here for mirrors (7009.92.5000) and if these mirrors are used with the bedroom furniture, they too are subject to ADD. Note, however, only wooden bedroom furniture from China is subject to ADD. If the article being imported is not wooden, if is not bedroom furniture, and if it not from China then it is not subject to antidumping duties. So, how do we know? We must confer with the Scope Information by Country. Here we can find a listing of all AD/CVD orders by country that includes the entire scope of the order as well as Scope Rulings that determines the exclusion of a specific item from the order. To find the AD/CVD rate most ABI systems have a case number query function that will return the current case with historical and current rates. There is an ADD CVD Search database on the CBP site and the rates are also distributed in the Federal Register. Antidumping and countervailing is a Priority Trade Issue (PTI) for CBP. AD/CVD case number formats, if you recall, were noted in our 7501 instructions. The case number is nine digits. The first three digits identify the country, the next three identify the item, and the last three identify the manufacture/exporter under the order. All case numbers are preceded with an “A” if under antidumping and a “C” if under countervailing. Entry Type 06: This entry is used to withdraw goods from a Foreign Trade Zone. Foreign Trade Zones (FTZ) may be used to place merchandise to be simply stored or further manufacturing may take place on the item placed in the zone, if allowed. Articles placed in the zone are put in with a particular status - either privileged foreign status, non-privileged foreign status, domestic status and restricted status. Merchandise of every description may be admitted into a zone unless prohibited by law. Many companies will import an item, or parts, and place them in the zone for further manufacturing into another article for withdrawal. This is a great benefit to importers. For example, many car parts average around 5.3% duty rates while the complete vehicle is 2.5%.

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Articles are entered into the zone on a CBP Form 214. We have included a copy of the 214 in your study materials (5.1a). This form is also now electronic and referred to as the e214. This form does not “clear the cargo” it allows submission of the articles into the zone. Foreign Trade Zones even get their own Part in CFR Title 19, Part 146. CBP has some additional information on their site at About Foreign-Trade Zones and Contact Info and the International Trade Administration has a page dedicated to FTZ as well as an Enforcement and Compliance page. There is much, much more to FTZ submissions and entries but since this is the ABC’s we’ll save those discussions for another class. Entry Type 11: This is entry type is referred to as an “informal entry” as well as “informal free and dutiable”. Cargo entered under an 11 entry type must not exceed $2500.00 in value, not subject to quota/visa, not subject to AD/CVD, and not utilizing a 9903 or 9904 additional HTS. Other than the value limit, informal entries are treated almost the same as a formal consumption entry – with the exception of how MPF and HMF are calculated. Entry Type 12: This entry type is referred to as an “informal quota/visa entry”. As with the 11 entry type to the 01, the 12 is to the 02. The 12 entry type is for shipments where the goods are subject to quota/visa that do not exceed $2500.00 in value. Entry Type 21: This entry type is referred to as a “warehouse entry”. This entry type is similar to but also very different from the FTZ submission; cargo entered in a warehouse entry may not be further manufactured and must be withdrawn in the same quantity measurements as entered. If 10 cases of something are entered into the warehouse, then articles must be withdrawn by the case. They may not be withdrawn by the “each” in the case. Cargo placed is a warehouse under entry type 21 (or entry type 22) may only stay in the bonded facility for five years then it must be withdrawn for consumption, exportation, or destruction. Any

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merchandise subject to duty may be entered for warehousing except for perishable merchandise and explosive substances (other than firecrackers). The duty rates applicable at the time of warehouse withdrawal will be the rate used upon withdrawal from the warehouse, not the duty rate at the time of the warehouse entry. Only HMF, if imported by ocean vessel, has to be paid against the entry type 21; all other duties, including IR taxes, MPF or other fees are paid at time of withdrawal. The warehouse entry allows IOR’s to postpone duty payments of the merchandise until it is withdrawn from the warehouse. When I owned my brokerage firm, I had a client who imported cigarettes. Between the duty and IR taxes a 40’ container of cigarettes could have up to $400,000.00 – yes $400,000.00 – due to the government. My customer utilized the warehouse entry to “store” his cigarettes until they were sold. Then he would do a withdrawal (entry type 31) for the amount of cases sold and would pay duty and taxes only on the cases withdrawn. Both the 3461 and the 7501 must be submitted for the warehouse entry. The “cargo release” 3461 is the authorization for the warehouse proprietor to receive the cargo into the bonded warehouse. Many importers use the warehouse entry when cargo arrives and the quota on the goods is filled. Warehouse and re-warehouse entries and withdrawals are covered in CFR Title 19, Part 144. Entry Type 23: This is called a “TIB” entry or “temporary importation under bond”. It is just as it is named – for merchandise arriving in the US that will only be here temporarily. This entry type is not use for cargo that will be consumed in the US. There are restrictions on the time allowed in the US under TIB, depending on what is being imported and why and there are restrictions to what may or may not be done to the cargo while it is here. Generally, TIB cargo is allowed to remain in the US for one year with a maximum of 3 years. The filer must request an extension each year if the cargo will remain beyond the first year. At the conclusion of the third year, the IOR must export, destroy, or enter the goods and pay appropriate duties plus 10%. Because of the special treatment of TIB cargo, when I had my brokerage firm, we had importers complete a TIB Request Form that

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contained the information of the shipment and their specific request for a TIB entry. Sample wording for the TIB request form:

T.I.B REQUEST LETTER (to be supplied on importers letterhead)

Date: I,______________ (authorized representative of the importer) hereby request that TIB entry be made in the name of ____________________(importers name) for our shipment arriving at _____________(port or arrival) for final delivery to _________________(port of entry) for Customs Clearance under TIB provisions. The shipment will be arriving on __________(date), via __________________(a/l or s/s) under MBL/MAWB number _______________________, for our PO/Invoice # ____________________. This shipment is being imported for the purpose of __________________________(give reason for TIB request). I understand that the merchandise must not be sold or that the articles are not to be put to any other use and that they are not imported for sale or sale on approval in anyway; that the merchandise must be exported under Customs Custody within one year from the date of import, unless lesser time is required by law, and if not, I will be responsible for all fines, penalties, and forfeitures as described in 19 CFR 10.31 – 10.40. Sincerely, ______________________ Name & Signature of authorized individual

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Entries under TIB must use a classification in Chapter 98, Subchapter XIII – Articles Admitted Temporarily Free of Duty Under Bond. It is important to read the notes as there are specific conditions for some cargo. For example, under Note 4 we see – District Directors of Customs may defer the exaction of a bond for not to exceed 90 days after the date of importation for vehicles and craft entered under heading 9813.00.35 to take part in races or other specific contests for other than money purses; but unless any such vehicle or craft is exported or the bond is given within the period of such deferment, such vehicle or craft shall be subject to forfeiture. Another key word to notice is “bond”. TIB cargo must have a bond posted, and the Port Director has the authority to determine the limit of the bond amount. Customarily the bond amount will be calculated the same as a continuous or single transaction bond, however, as mentioned, the Port Director where the cargo is being admitted may and can require specific bond limits. TIB is one entry type that can be changed after the cargo release and before the entry summary is presented. If a TIB was elected, then the IOR decides before duty payment is due to change the entry to a consumption that is permissible and proper duties must be paid. However, if the IOR initially submits an entry as a consumption entry then wants to change it to a TIB, the Port Director may deny the request. The reason is that CBP has the right to examine all cargo being imported and many times will require an exam of TIB cargo at the time of exportation. If the cargo was entered as consumption and CBP did not examine it, then there would be no account of what initially arrived to confirm the exact item is being exported. CBP may waive the exam requirement at time of export and the filer must confirm if exam is required or not. The ACE system should generate the requirement or waiver when the TIB is submitted and released. The cancellation of a TIB must be done under Customs supervision and will have to move under bond (IE or T&E) to the port of export. The IE or T&E will have to be validated by CBP and should contain the entry number along with all import and export details to allow CBP to quickly authorize the export and cancellation of the bond.

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More information about TIB’s can be found in CFR Title 19, Part 10 and in Chapter 98 of the HTS. Entry Type 31: This is a “warehouse withdrawal - consumption” and is used in conjunction with the Warehouse Entry, type 21 or Re-warehouse Entry, type 22. The 31 entry type is used for withdrawing cargo from the bonded warehouse that is not subject to quota/visa or antidumping/countervailing duty. Other withdrawal entry types are used for quota/visa (32 or 38) and AD/CVD (34 or 38). As noted above, cargo entered into a bonded warehouse under an entry type 21 or 22 must be withdrawn using one of the warehouse types within 5 years of the cargo entering the bonded facility. The warehouse proprietor and the entry filer, as well as the IOR, must keep accurate records of the entry and release of the bonded cargo. As cargo is withdrawn the warehouse entry decrements the original quantity with each withdrawal until there is a zero balance. Once all the cargo entered under the warehouse entry has been withdrawn the filer and the warehouse proprietor must submit what is called closing documents to CBP. Remember, cargo must be withdrawn in the same quantity units in which it is placed into the warehouse. The above entries are subject to the regulatory authority of other government agencies – there are 47 others – and when the filer (by the way, we say filer because importers may file their own entries so simply saying broker would be incorrect and misleading) submits the entry information in ACE all agencies requirements must be satisfied. If the filer of the entry is a broker, they must possess a valid Power of Attorney (POA) issued by the importer of record authorizing the broker to act on the importer’s behalf. Entry of Merchandise and Entry Process are covered in CFR Title 19, Parts 141 and 142, respectively. In Week 7, we will review some of the requirements outlined in these Parts as they truly lay out the “law of the land” for entry purposes. If you recall, we have looked at some of the requirements of the broker in Part 111 and we’ll see how 111 ties brokers

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and importers together in 141 and 142. This is why the POA is so very important and why the relationship between the importer and the broker must go beyond vendor-client to a true partnership. Entry Type 41: Manufacturing Drawback – this is when cargo is imported into the US and further manufactured then exported back out of the country. Companies who participate in drawback are eligible to get 99% of the duty paid on the imported product refunded. There are many rules and special requirements for companies to enjoy the benefit of duty drawback. For example, under the new Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA) the time frame to which cargo must be exported after importation has been extended, the imported product seeking drawback must be exported within five years of the import date. Entry Type 42: Same Condition, this is now referred to as Unused Merchandise Drawback but some of us old timers still call it same condition. For imported cargo to have drawback benefit under this entry type the imported article must be in the same condition, or unused, at the time of export. Some of the same rules apply for entry type 42 as with the 41 and 43 entry types, but depending on which drawback type is being claimed will depend on the specific set of rules that have to be followed. Entry Type 43: Rejected Importation Drawback is just as it is named – for imported cargo that is being rejected due to quality, functionality, or other reasons allowed by CBP. Drawback entry is a very specialized type of entry and many brokers do not file these. In fact, there are quite a few brokers in the US that only do drawback entries. Drawback is covered in CFR Title 19 Part 190 –Modernized Drawback, and Part 191 – Drawback. Filers of drawback entries must have a valid POA from the drawback claimant. The next three entries we will discuss are not entries that allow the clearance of cargo for consumption in the US. Also, while covered in CFR Title 19 – Customs Duties – Part 18, these entries are not considered “customs business” therefore they do not have to be performed by a license customs broker. (I won’t get on my soap box about the definition of

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“customs business”… you’ll see what I mean after you have been in international trade and logistics for a while). Because these entries are not customs business, a POA is also not needed to process a 61, 62, or 63 entry type. All other entries above require the broker to hold a valid power of attorney from the importer. However, penalties can be issued by CBP for violations pertaining to these entries (hence the reason for the bond). Entry Type 61: This is the “Immediate Transportation” or “I.T.” entry. This entry is used to move cargo throughout the US under Customs supervision and as bonded cargo. As noted above, this entry does not clear cargo for entry and consumption in the US, it allows cargo to move under bond in the US. Many importers take advantage of the benefits allowed under the IT as cargo can arrive at one port, for example New York, then move to another port, for example Atlanta, to clear customs. This practice was allowed by CBP many years ago and enabled the importer to receive their merchandise before they had to pay duty on it. Duty, generally, is due to Customs within 10 working days from the release of the goods. It can sometime take 7-14 days for cargo arriving in the west coast to reach the east coast, so without the benefit of IT, importers could be paying duty before the cargo even gets to their warehouse. Carriers, forwarders, and brokers can submit IT entries to CBP. Yes, these have to be submitted to CBP and approval given for the cargo to move under bond and under CBP supervision from one port to another. The bond is in place by the carrier and is there to ensure CBP gets their proper duty, tax, and fees on the importer cargo once cleared for entry into the US. The IT is also used when cargo here in the US needs to move under bond or under Customs supervision for the movement of re-warehouse cargo and for a host of other reasons. Mostly the IT is used to move cargo from a port of arrival in the US to a port of entry in the US. If you remember when we reviewed the 3461 Cargo Release and 7501 Entry Summary we noted how the IT number must be reported on these documents if applicable. Entry Type 62: Transportation and Exportation (T&E) entry is, like some of our other entries, just as it is named. This entry is for the cargo moving under bond and under Customs supervision that is being transported from

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one port in the US, like Atlanta (1704), to a different port, like Charleston (1601), for export out of the US. This entry type is used in conjunction with entries like drawback or when a TIB needs be cancelled. Entry Type 63: Immediate Movement Exportation (I.E.) is similar to the T&E except it is for cargo that is immediately exporting from the US from the port where the cargo is. As with many of the entry types we have reviewed the 61, 62, and 63 entry types are now filed electronically. While the filer of the transportation entry does not need a POA, the issuer of the transportation entry must have POA from the bonded carrier that will move the cargo if the issuer is not the carrier themselves. Entry Type 86: This entry is known as the “Section 321” entry. Only recently has this entry become an electronic entry and as of this writing (2019 – Trade ACE Information Notice) it is in the pilot stage for ACE functionality. This entry also was greatly modified by the TFTEA. Prior to TFTEA the 321 entry was limited to $200 De Minimis and under TFTEA it is $800 per shipment. There are many restrictions to the use of the 321 including, the cargo must not be subject to quota/visa, AD/CVD, 232 prohibitions, 301 tariffs, and others outlined in the Act. If the merchandise is regulated by any other government agency, as with other entries, that agency data must be submitted with the entry data transmitted in ACE for cargo release. The 321, however, will not require the submission of the 7501 Entry Summary data nor will any duties be required; if the shipment requires fee collection (e.g. agricultural fees), filers must file a Consumption or Informal entry. The regulations covering the 321 can be found in CFR Title 19, Part 10, specifically 10.151. CBP has an Entry Type 86 Frequently Asked Questions page to help filers in the processing of the “321” entry. Many of the ABI software systems are programed to help guide the user to the correct entry type by “flagging” certain HTS numbers paired with countries of origin and other algorithms that aid the filer. Based on the information keyed into the system, the user could see warnings such as “may be subject to ADD” or “entry type not allowed”. When the user sees

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the “may be” warning is it imperative to confirm if the “may be” is or is not. These messages also will warn the use if another government agency information is required whether mandatory or optional, “is required” verses “may be” required.

⇔ After reviewing some of the entry types for cargo clearance and movement, discuss with your classmates some the information we must have to help us determine an entry type. Post your comment in the discussion forum titled “Determining Entry Types”.

⇔ Review the Determining Entry Types Assignment (5.1) document and upload your answers in the “What Entry Type and Why” link.

Week 5 Lesson 2 – Importer Security Filing (ISF) Import Security Filing (ISF) was introduced to us on November 25, 2008 in Federal Register Vol. 73 No. 228 (73 FR 71729) through a mandate from section 203 of the Security and Accountability for Every (SAFE) Port Act of 2006 and section 343(a) of the Trade Act of 2002, as amended by the Maritime Transportation Security Act of 2002. Now, ISF is only required for certain cargo arriving in the US by ocean vessel. At its conception, ISF was called “10 + 2”. I joked and said, “Well, why don’t they just call it 12.” After understanding the rule, 10 + 2 is more appropriate than simply 12. Because, 10 of the data elements must be filed by the importer, or their authorized agent – I’ll get on my soap box about this too – and two of the data elements must be filled by the carrier. ISF is another one of those required filings that is not customs business, but the authorized agent must hold a valid POA, a bond must be posted, it has its own Part in CFR Title 19, Part 149, and penalties can be issued to the importer if violations occur. In your study materials, labeled 5.2 2018 ISF FAQ, is the most updated ISF guidance material CBP has published. It is dated November 2018. This FAQ will provide you with many insights to the ISF requirements. As you review the materials pay close attention to the timing requirements, the specific data elements that have to be submitted, what can be changed

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and when, agents and brokers – when the same must be used and when multiple entities may be used, exclusions to bond requirements as well as exclusions from ISF requirements. While not included in the FAQ, below are some very important codes you will want to know when filing ISF. These codes are generated by the government (CBP) to the filer so the filing status may be known. Violations can result in penalties. And customs entry cannot be made without this filing; therefore the filer must ensure they received the golden S1 to allow customs entry to be made.

• S1 Bill of Lading Matched to Importer Security Filing: Generated to the party filing the Importer Security Filing when the ISF is matched with a bill on file with CBP.

• S2 Bill of Lading not on file: Generated to the party filing the

Importer Security Filing when the ISF does not match a bill on file with CBP.

• S3 Bill of Lading not on file 5 days after filing the ISF: Generated to

the party filing the Importer Security Filing when the ISF does not match a bill on file with CBP within 5 days after the ISF is received.

• S4 Bill of Lading not on file 20 days after filing the ISF: Generated to

the party filing the Importer Security Filing when the ISF does not match a bill on file with CBP within 20 days after the ISF is received.

• S5 Bill of Lading not on file 30 days after filing the ISF: Generated to

the party filing the Importer Security Filing when the ISF does not match a bill on file with CBP within 30 days after the ISF is received.

• S6 No Bill Match (Wrong Type): Generated when the ISF bill is on

file in AMS as a different bill type.

• S7 Duplicate ISF By Another Filer: An ISF with same Bill Number and Importer of Record has been filed by another filer.

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• SA No Bill Match (Wrong Type): Generated when the ISF bill is on

file in AMS as a different bill type, 5 days after filing the ISF

• SB No Bill Match (Wrong Type): Generated when the ISF bill is on file in AMS as a different bill type, 20 days after filing the ISF

• SC No Bill Match (Wrong Type): Generated when the ISF bill is on

file in AMS as a different bill type, 30 days after filing the ISF. CBP has an Importer Security Filing '10+2' page on their site where you can get additional information on ISF. Also included in your study materials is an ISF Advise Sheet (5.2a) that helps to outline the needed information for an ISF. ISF, as we mentioned is only for cargo arriving in the US by ocean vessel and is the responsibility of the importer (10 elements) and the carrier (2 elements). There is also a cargo security data requirement for cargo arriving by airfreight; however that responsibility lies solely on the carrier. The forwarder, shipper, or other party of interest could provide data to the carrier for submission to CBP and TSA. This security measure is called Air Cargo Advanced Screening (ACAS).

⇔ Using the Commercial Invoice and Ocean Bill of Lading provided in your Week 5 study materials, and recalling the HTS numbers used in Week 4 to complete the cargo release and entry summary for the airfreight shipment, include the proper ISF HTS numbers, complete the ISF Advise Sheet and upload it.

⇔ Discuss with your classmates why cargo security is important. Week 5 Lesson 3 – Carnets A Carnet is quite special. It serves as both an entry and a bond. Similar to TIB cargo, the Carnet allows cargo to temporarily be in the importing country and cannot be sold (well, without penalty anyway). Therefore, Carnet cargo may enter the US, but not enter the commerce of the US. Carnets can only be issued by companies who have been approved by the

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International Chamber of Commerce (ICC). Mullins International Solutions is authorized to issue Carnets under Roanoke Trade. As well, we are the Atlanta processing and pick up location for Roanoke ATA Carnet. Currently, Carnet is a paper based entry type – it is not processed in ACE. An electronic version of Carnet is being developed and tested. Because it is paper based, ports may have different processing procedures. Carnet cargo, in many cases and similar to TIB cargo, will be examined at the time of import and at the time of export. Cargo on the Carnet must be itemized by the piece, not the carton count. The manifest and approval for import is, however, done at the carton level. The United States Council for International Business (USCIB), Roanoke Trade, and CBP has further detailed information about Carnets. Roanoke Trade has an ATA Carnet sample you can review.

⇔ Review the ATA Carnet Sample and the ATA Carnet presentation ⇔ Discuss with your classmates the benefits of using a Carnet

Week 5 Quiz

⇔ Take the Week 5 quiz of 25 questions