From OFF THE CUFF October 2011 Issue
By Mary Jo Muoio, Senior Vice President, OHL Trade Services
I recently read that the average person is believed to have 70,000 thoughts a day. Since our work is not for the average individual, it’s a sure bet that we exceed that number every day just thinking about the import clearance of our goods. The import process is exceedingly complex. It’s no wonder we don’t have time to think about lunch!
I also read that the Sinclair ZX81 computer, which went on sale 30 years ago, had a 1KB memory. You would need 50,000 of them to run iTunes—think about how many you would need to just purchase, transport, invoice, declare, pay, receive, sell and record the transactions on the goods you import! Between using up valuable daily allotments of thoughts and valuable IT resources, it is obvious that there is room for simplifying the import process.
The good news is that U.S. Customs and Border Protection (CBP) agrees that it’s time to find ways to simplify the entry process. CBP recognizes the connection between economic and national security, and has been focusing on what they can do to help importers remain economically viable. Entry simplification may be a means to help importers.
To take entry simplification from thought to action, CBP gathered a group of representatives from diverse trade groups to brainstorm ways to simplify the declaration and clearance processes by looking at ways to align them with businesses practices. Rather than requiring business to adopt processes designed just for entry, perhaps there are ways that existing business practices could be adapted to meet government needs.
The first attempt at entry simplification will focus on the simplification of the release process, and concepts to streamline the current entry summary and payment processes may follow.
CBP will publish a Federal Register notice on a pilot for entry simplification. While the specifics will be detailed in the notice, advance announcements indicate that the concept will be a single declaration rather than separate Importer Security Filing and Entry/Immediate Delivery (CBP Form 3461) declarations. CBP will review a core set of data elements which include:
Importer of record
Buyer name and address
Shipper name and address
Ship to name and address
Manufacturer/supplier name and address
10 digit HTS number
Country of origin
Bill of lading/house bill/ AWB number
Container number
Container stuffing location (mode specific)
Estimated value
Entry number
This list may look familiar. CBP has added just a few data requirements to the existing ISF data set. In order to act as a simplified entry, this declaration will be submitted to CBP early enough to satisfy ISF requirements; specific timing for all modes will be outlined in the upcoming announcement.
As a pilot, there will be limitations on participation. It seems that in order to participate in the pilot, the following must be met:
- only entry types 01 (Consumption) and 11 (Informal) will be accepted
- the entry must be covered by a continuous bond
- the port of arrival, unloading and entry must be the same location
- the house bill and manifest quantity must be the same
- there cannot be any other government records transmitted
- The ISF importer and importer of record must be the same party
- the entry summary must be filed in ACE
CBP may also require that the importer be a C-TPAT Tier 2 or Tier 3 company.
If you’re wondering whether this pilot is a good option for your company, you should meet with your broker and fully discuss the requirements and merits.
If this process reduces the things to think about and systems to accomplish the efficient importation of goods, it may simplify our businesses. Then, we can think about lunch!
Mary Jo Muoio is Senior Vice President at OHL Trade Services (http://www.ohl.com/), a USA-ITA Associate Member. Before assuming leadership of the consulting division, Ms. Muoio was a Senior Vice-President of Barthco International, Inc., a leading customs broker and forwarder acquired by OHL. Ms. Muoio has been with OHL for over 25 years. Ms. Muoio spoke at our trade policy symposium in July 2011.
