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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.

Insights

Client Alert | 3 min read | 01.13.26

Colorado Judge Quashes DOJ Gender-Related Care Subpoena

On January 5, 2026, District of Colorado Magistrate Judge Cyrus Chung issued a recommendation that the district court grant a motion to quash a Department of Justice (DOJ) administrative subpoena that sought records about the provision of gender-related care by Children’s Hospital Colorado (Children’s) in In re: Department of Justice Administrative Subpoena No. 25-1431-030, U.S. District Court for the District of Colorado, No. 1:25-mc-00063. The court concluded that the DOJ had failed to carry its “light” burden, noting that no other courts that had considered the more than 20 similar subpoenas issued by DOJ had ruled in the DOJ’s favor.  ...