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Importer Security Filing Update: Enforcement Begins This Month, Bond Requirements Clarified
Enforcement of the Importer Security Filing (ISF) will begin on January 26, 2010. At that time, Customs and Border Protection (CBP) will begin issuing penalties of $5,000.00 as well as potentially holding cargo at origin for noncompliance. The ISF, also known as “10+2”, became a requirement on January 26, 2009 for all U.S. ocean import shipments. All importers are strongly encouraged to begin filing ISF transactions immediately.
As of December 6, 2009, CBP had received 3.65 million security filings from 1,950 approved parties representing 103,000 importers. CBP is now receiving 110,000 per week directly from importers or their agents. Three percent of filings are incomplete or have errors and the on-time filing rate is in the 50 to 60 percent range. Compared to the total volume of customs entries received, it is estimated that the total filing rate is 80 percent (American Shipper Magazine).
Bond requirements have been a somewhat gray area, but are starting to take more definite shape. ISF filings will be covered by an importer’s continuous entry bond. Importers may also elect to take out an additional continuous bond to cover ISF exclusively. Bond requirements are detailed in the table below.

“We doubt that CBP will show leniency on those to who fail to comply with ISF after January 26th” quotes Venetia Huffman, CVI Vice President of Operations & Compliance. In addition, she encourages all importers to quickly pursue obtaining a CBP continuous bond exclusively for ISF purposes. Having a bond for exclusive ISF use will prevent the importer from refusal of ISF services by brokers or other third party filers who are unwilling to assume liability against their own bonds and it will split their liability for any infractions. “If bond limits are reached as a result of ISF penalties under a continuous bond used for entries and ISF, it could risk the importers ability to file entries,” stated Huffman.
Please contact your CVI customer service representative or e-mail isf@cvinternational.com for information on how we can assist you with compliance.
Click here for more information about ISF>>
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