Importer Security Filing and Additional Carrier Requirements

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• Importer Security Filing and Additional Carrier
  Requirements

102 Program
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What is the Security Filing?

• The Security Filing, commonly known as the 102
  initiative, is a Customs and Border Protection
  (CBP) regulation that requires importers and
  vessel operating carriers to provide additional
  advance trade data to CBP pursuant to Section 203
  of the 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, for
  non-bulk cargo shipments arriving into the United
  States by vessel.

Importer Requirements U.S. Bound Cargo
(Includes FTZ and IT) requires the electronic
filing of an Importer Security Filing (ISF)
comprised of 10 data elements. Transit Cargo
(FROB, IE and TE) requires the electronic filing
of an Importer Security Filing (ISF) comprised
of 5 data elements.
Carrier Requirements Vessel Stow Plans required
for arriving vessels with containers. Container
Status Messages required for containers arriving
via vessel.
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Security Filing Requirements

• All ISF filings are to be done electronically via
  vessel Automated Manifest System (AMS) or the
  Automated Broker Interface (ABI).
• There will be no paper forms (e.g., CBP Form 3461
  equivalent).
• Note CBP is not creating an internet-based web
  portal to accept the ISF filings. However, some
  service providers allow self-filers indirect
  access to CBP systems.

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Data Elements (10)

• Importer of Record Number
• Consignee Number
• Ship to Party
• Manufacturer ( Supplier) Name/Address
• Country of Origin
• Commodity HTS-6
• Container Stuffing Location
• Consolidator (Stuffer) Name/Address
• Foreign Port of Lading
• Place of Delivery

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102 Impact to Forwardering Companies

• Additional cost to service same customers.
• Additional Employees.
• Additional Man-hours.
• Delay in getting some cargo loaded into
  container.

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WHAT IS TWIC?

• Transportation Worker Identification Credential

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Effective Date vs. Compliance Date

• Effective Date The Interim Final Rule took
  effect on January 26, 2009 (60 days after the
  publication date).
• Compliance Date 12 month delayed compliance
  period from the effective date to allow industry
  to comply with the new requirements. January 26,
  2010.
• The 12 month delayed compliance period may be
  extended if circumstances warrant.
• Structured Review Period
• Flexible Enforcement
• Robust Outreach Program
• Public Participation

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TWIC Impact to Trucking Companies

• Additional cost in to service same customers.
• TWIC card needed for pick up deliveries to all
  ports.
• Some drivers do not meet minimum requirements to
  get TWIC card.

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Trucking Company Impact When U.S. Ports are Shut
Down

• Revenue losses.
• Local drayage companies have no work.
• OTR trucking companies have an equipment
  imbalances.

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Economic Impact of a Disaster at a United States
Port

• Resulting in billions of dollars lost to the
  United States economy each day the ports are
  closed.
• Every day, 30,000 trucks, 6,500 rail cars and 140
  ships deliver more than 50,000 such containers to
  destinations within the United States.
• Stock market