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November 7, 2008
It is our understanding that the OMB review process is complete and publication of the new regulations may occur as soon as next week. For background information on the 10+2 Importer Security Filings visit our web page, “10 + 2 What Does It Mean For You?”.
It is our understanding from published sources that implementation of the new requirements be subject to a mandatory 60-day Congressional review period (essentially a 60-day delay) and then one year of informed compliance.
A comment period will begin on June 1, 2009, giving the trade community an opportunity to describe what is working and what is not, and based on those comments, the Obama administration may decide to continue moving forward as it is, or make modifications if there are a lot of negative comments.
The data elements have been divided into two tiers, which are broken out below. Tier I will go into affect as CBP originally envisioned. A start date for providing Tier II information has still not been established. As originally envisioned, all data elements will be required 24 hours before loading the vessel.
Tier I Information
- Importer of record number
- Seller name & address
- Buyer name & address
- Consignee number
Tier II Information
- Manufacturer/supplier name & address
- Ship to name & address
- Country of origin
- Container stuffing location name & address
- Consolidator name & address
- Tariff number
If you have questions about the above, please contact George Tuttle, III at (415) 986-8780 or geo@tuttlelaw.com.
George R. Tuttle, III is an attorney with the Law Offices of George R. Tuttle in San Francisco.
The information in this article is general in nature, and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence, and may not be considered as such.
Copyright © 2008 by Tuttle Law Offices.
All rights reserved. Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information. |