C. F. Lynch & Associates

When 10 + 2 Doesn't Equal 12

By Clifford F. Lynch

DC Velocity, November 2009

Unless you’re involved with international cargo shipping, you can be forgiven for thinking that "10+2" simply equals 12. From what I gathered at the recent conference of the Council of Supply Chain Management Professionals, the term – which refers to a cargo security initiative that took effect in January – has yet to gain universal recognition. While many conference attendees had at least a passing familiarity with the term, there were plenty of others – particularly those who deal largely with domestic shipping – who didn’t seem to have a clue.

The lack of awareness can’t be put down to a scarcity of information. A fair amount has been written about 10+2, particularly by those who are involved with it. Nonetheless, a surprisingly large number of supply chain practitioners appear to be vague on the details. This, then, will be an attempt to explain 10+2 to those who are interested – to those of you who aren’t, now would be a good time to flip the page.

Officially known as the Importer Security Filing (ISF) and Additional Carrier Requirement, the 10+2 rule is intended to help the U.S. Bureau of Customs and Border Protection (CBP) screen incoming ocean containers for security risks. About 7 million containers are unloaded at U.S. ports each year, each offering a potential opportunity for terrorists and smugglers to bring dangerous or banned material into the country. CBP believes that by gathering information about these imports before they arrive on U.S. shores, it will be better able to target high-risk shipments for further inspection.

Under the rule, both importers and carriers must submit specific information on the cargo prior to its arrival in the United States. Importers are responsible for providing 10 data sets for each container; ocean carriers are required to provide two additional sets – hence the name "10+2."

Importers must submit their date to CBP electronically 24 hours before a container is loaded onto a ship bound for the United States (with two exceptions, noted below). This is the ISF transmission and consists of:

      Name and address of seller

      Name and address of buyer

      Importer of record number

      Consignee number

      Manufacturer or supplier

      Ship-to party

      Country of origin

      Commodity Harmonized Tariff Schedule number

      Container stuffing location*

      Consolidator name and address*

    *This information is not required before loading but must be provided no later than 24 hours prior to the container’s arrival at the port.

Carriers are responsible for providing the last two data elements, which they must do no later than 48 hours after the ship’s departure from the port of origin. The elements are:

      The vessel stow plan

      Container status message data, which must be provided within 24 hours of the time the information is entered into the carrier’s equipment tracking system.

To further complicate matters, there is the issue of containers that remain on board after cargo is discharged at a U.S. port. For this cargo, five data elements must be transmitted 24 hours prior to loading. These are:

      Booking party name and address

      Ship-to party

      Commodity Harmonized Tariff Schedule number

      Foreign port of unloading

      Place of delivery

Although importers and carriers have already developed methods of gathering and transmitting data that ease the burden, it’s clear that complying with 10+2 is a cumbersome procedure. What’s not co clear is whether all that effort is justified for an initiative whose effectiveness, I believe, is questionable.



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