U.S. Customs and Border Protection officials are saying CBP will take a “measured approach” to enforcing the 10+2 Importer Filing (ISF) requirements. Enforcement of the 10+2 requirements is scheduled to begin Jan. 26, after a one-year delay in enforcement.
CBP has said it will use a “graduated enforcement” policy over the next year. Through April, CBP will focus on importers who have not made ISF filings, with their shipments more likely to be subject to inspections. CBP also will look closely at importers with late or incomplete filings. CBP officials say they do not plan to issue Do Not Load messages or assess liquidated damages during this time period but reserve the right to do so if deemed necessary.
Beginning in May CBP intends to issue holds on cargo for noncompliance, though officials say they don’t expect to issue many Do Not Load messages or assess liquidated damages at that point.
By August or perhaps shortly thereafter, CBP likely will begin to assess liquidated damages on ISF filings. By October, CBP officials say they expect to be in full enforcement mode.
AFI is planning to have a session on 10+2 at the AFI Convention April 29-May 2 in Delray Beach, Fla. and is exploring the possibility of conducting a webinar on 10+2 as well.
