Few Are Ready for 10+ 2. Are You?
A December 2009 study reveals that as few as 22 percent of companies are ready for the
January 26, 2010 mandate date for full Importer Security Filing (ISF) " 10+ 2" compliance. The
economic recovery may foretell huge fines for these companies.
—Bob Heaney, senior research analyst, Supply Chain Execution, Aberdeen Group
n the post-9/11 era, no issue is more important to the future
of ocean transportation than security. Shipping containers
pose a devastating risk both of physical and economic loss
should a weapon be smuggled into a port. In response to these
inaccurate or missing data.
In Aberdeen’s December 2009 study, Supply Chain Visibility Excellence: Reduce Pipeline Inventory and Landed Cost,
there were 174 importers surveyed and only 22 percent said
risks the U.S. Department of Homeland Security and U.S. Customs they had visibility to the 10 required elements and only 48
& Border Protection (CBP) has enacted a new regulation known as percent of them are confident their carriers are prepared to
the “ 10+ 2” rule. On November 25, 2008, the CBP released this rule supply the remaining 2 elements.
on importer security filings (ISF) and as of January 26, 2010 the
penalty phase will begin. The “ 10+ 2” rule makes for a more com-
plicated filing because it is a two-party process that requires: 1) In 2010, compliance issues will become even more impor-importers to provide CBP with 10 data elements about ocean ship- tant. According to the monthly Port Tracker (by the National
ments inbound to the U.S. at least 24 hours prior to vessel depar- Retail Federation and IHS Global Insight, November 2009),
ture, and 2) ocean carriers to provide 2 data messages at least 48 import container volume at the nation’s major retail container
hours prior to vessel departure.
ports in February 2010 is expected to increase 16 percent
This rule applies to all maritime cargo loaded at a foreign over February 2009. This represents a break from a 31-month
port that is destined for direct discharge at or transiting through string of year-over-year declines. The NRF is hopeful that this
a U.S. port, and companies will face significant fines if they are is a sign of economic recovery, but companies should be
not in compliance with the new regulation. Penalties include mindful that increased shipments with noncompliance to
liquidated damages equal to the value of a shipment for failure “1 0 + 2” c o u l d l e a d t o s i g n i f i c a n t e c o n o m i c p e n a l t i e s ,
to file the ISF, and importers may also face potential charges for impounded cargo and delays.