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Customs 10+2 Initiative


Importers face a new filing obligation arising before the entry documents are filed, and indeed before merchandise is even loaded into a container: a recent Customs proposal would mandate the submission of an Importer Security Filing ("ISF") 24 hours prior to container loading. The ISF would require ten data fields, including:

(1) Manufacturer (or supplier) name and address
(2) Seller (by owner) name and address
(3) Buyer (or owner) name and address
(4) Ship-to name and address
(5) Container stuffing location
(6) Consolidator (stuffer) name and address
(7) Importer of record number/foreign trade zone applicant identification number
(8) Consignee number(s)
(9) Country of origin
(10) Commodity Harmonized Tariff Schedule number

Customs is accepting comments on the proposal, known as the "10 + 2 Rule," until March 18, 2008. To date, the trade has been critical of the proposal because compliance with the ISF filing requirements will alter the way many companies do business. Creating new data gathering systems will be a significant burden, and many transactions (particularly CIF sales, which would make compliance with the rule difficult) now will require entirely new commercial arrangements.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Alexander H. Schaefer
Partner – Washington, D.C.
Phone: +1 202.624.2773

Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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