Customs 10+2 Initiative
Client Alert | 1 min read | 02.11.08
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.
Contacts
Insights
Client Alert | 4 min read | 04.02.26
FTC Announces New Health Care Task Force
In a development likely to ramp up regulatory pressure on an industry already under significant federal scrutiny, Federal Trade Commission (FTC) Chairman Andrew Ferguson recently directed leaders across his agency to launch a team dedicated to cooperatively advancing enforcement and advocacy activities relevant to health care.
Client Alert | 7 min read | 04.02.26
Reducing Your Exposure: Liability Limitations for Cybersecurity-Compliant Organizations
Client Alert | 4 min read | 04.01.26
Client Alert | 5 min read | 04.01.26

