Trade knowledge / The US Importer Security Filing and the EU Entry Summary Declaration
Date: 2013-08-05
The US Importer Security Filing and the EU Entry Summary Declaration
Since the earliest days of Christopher Columbus and shipping goods around the globe, customs authorities at destination first learned of a shipment’s existence as it arrived within the port limits and customs territory. This notification came in the form of a manifest prepared and filed by the carrier of the goods. These manifests usually contained very vague descriptions of the cargo, which was then followed by a more detailed customs declaration by the importer or consignee.
Times have changed. Today customs authorities require detailed data before a consignment departs at origin, allowing time for customs to screen the shipment for security purposes and to target suspect shipments with greater granularity.
In the US, a pilot launched following the attacks of September 11, 2001, was first called the Advanced Trade Data Initiative, which then gave way to the moniker 10+2 (10 data elements provided by the importer and two provided by the carrier). When formalized the program ultimately became known as the Importer Security Filing (ISF).
This January, the US ISF program will mark its second full year of phased-in operation. Also this January, the 27-member states that make up the European Union (EU) will collectively launch their version of the ISF. On January 1, 2011, all goods entering the customs territory of the EU will be required to have an Entry Summary Declaration (ENS) on file.
The Exit Summary Declaration (EXS) reporting requirement for exports from the EU has been in effect since July of 2009, and the ENS filing has been running concurrently on a voluntary basis for EU imports. Each of the 27-member states have been actively establishing their programs albeit on slightly different time schedules and in some cases using different names. For example, the U.K. is scheduled to begin testing of their version of ENS called the ICS (Import Control System) on November 2, 2010. HM Revenue & Customs has posted an extensive FAQ on their web site related to ICS that can be accessed on their website.
The primary differences between the ISF and ENS are twofold. First and most importantly, unlike its ISF counterpart, which is filed by the importer and the carrier, the carrier is solely responsible for filing the EU's ENS declaration. The carrier also has the option of appointing an agent to file on their behalf.
Second, the ENS declaration requires 22 data elements, almost double the 12 data elements required for the ISF. The ENS data elements are:
Seller/Consignor (EORI #)
Buyer/Consignee (EORI #)
House BL Number
Master BL Number
Carrier
Person Entering the Filing
Notify Party
Country of Origin
At least the first four digits of the HTSUS Number (Commodity Harmonized Tariff Schedule of the EU)
Place of Loading Location
First Port of Entry in EU
Description of Goods (Not required if four or six digit HTS is provided)
Packaging Type Code
Number of Packages
Shipment Marks and Numbers
Container Number
Container Seal Number
Gross Weight in Kilos
UN Dangerous Goods Code
Transportation Method of Payment Code
Date of Arrival First Port EU
Declaration Date
To preclude January delays, shippers to the EU would be well advised to spend the next few months working on timing, data flow and communications with their forwarders and carriers. This includes a complete understanding of who will provide the data, who will make the filing, and the timing associated with lodging the ENS. Non-containerized maritime shipments to the EU are subject to pre-arrival (rather than pre-loading) filing requirements with the exact deadlines depending on whether the vessel is deployed in deep sea or short sea shipping lanes.
For more information on the EU’s ENS requirements, including a comprehensive FAQ, visit the European Customs Information Portal.
Savvy shippers will also take this opportunity to review and correct (where necessary) product descriptions of the cargo being shipped. General and vague terms like "freight all kinds" or "general department store merchandise" are no longer acceptable to carriers or customs administrations. In fact some customs administrations (especially here in the US) are putting a much greater emphasis on requiring importers to provide very detailed descriptions of the goods they are importing.
In fact, last month a US Customs and Border Protection (CBP) National Account Manager issued an ominous public warning about CBP's increased scrutiny. According to this individual, CBP recently updated and adjusted the compliance measurement criteria in the Automated Commercial Environment (ACE), and those adjustments will ultimately result in many more Requests for Information (CF-28) from CBP.
Shippers are strongly encouraged to review the product descriptions they are using on commercial invoices. If the item being reviewed cannot be completely visualized, they should consider adding additional detail to the description field. This might provide some significant challenges for shippers with limited systems capability or size restrictions on the length of the product description within their legacy systems.
In the meantime, as the EU prepares to move to the mandatory phase of their program, the US Government Accountability Office (GAO) issued a 52-page report in September on the ISF program. For a copy of the GAO report on ISF, visit the GAO website. According to CBP data, approximately 80% of all importers in July of 2010 were ISF compliant. The report concluded that the ISF requirements have not measurably impacted the flow of commercial trade.
CBP's phased enforcement of ISF continues to move forward, and it is widely speculated that the first installment of ISF penalties could be issued as early as this January. To date CBP continues to work with importers who are not filing ISF,s on their shipments by detaining and inspecting those consignments.
By any name—ISF, ENS or ICS—such advanced reporting schemes amount to a significant change in the timing and the way that this information has been reported for centuries. Shippers are encouraged to take advantage of these changes to "clean-up" and strengthen the quality and accuracy of their trade data.
( linda )05 Jan,2012
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