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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.

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Client Alert | 7 min read | 05.21.26

A New Playbook for M&A in the EU: The European Commission's Draft Merger Guidelines - 10 Key Changes

On 30 April 2026, the European Commission published draft merger guidelines that will replace both the 2004 Horizontal Merger Guidelines and the 2008 Non-Horizontal Merger Guidelines, consolidating them into a single analytical framework....