Tuesday, December 2, 2008

New Importer Reporting Requirements

Last week the US Customs and Border Protection published an interim final rule posing new cargo security requirements for maritime carriers and importers. I don’t often watch for CBP notices in the Federal Register, but I read the DHS press release and it struck me that this might apply to chemical facilities importing raw materials. It’s a lengthy IFR, 50+ pages in the Federal Register, so I haven’t had a chance to review it yet in detail. Once I have a chance to review this in more detail, I’ll decide whether it might be of more interest to readers of this blog. Flexible Enforcement Period The rule goes into effect on January 26th, 2008 but there a at least three separate compliance dates listed in the IFR. According to a DHS Fact Sheet there is a “delayed compliance date of 12 months after the interim final rule takes effect” (1-26-10). During this period enforcement efforts will take into account importer difficulties in setting up effective policies and procedures to implement the rule so long as “importers are making a good faith effort and satisfactory progress toward compliance”. Structured Review This rule apparently provides for some radically new procedures for information submission. CBP will be conducting a detailed, structured review of these requirements. The data gathering portion of this review will continue until 6-1-09. Part of that data gathering will be the request for public comments on some specific elements of the rule and their affect on importers. According to the fact sheet DHS will use this analysis to “determine whether to eliminate, modify or maintain these requirements.” Bad Link Note I had some minor difficulty finding this IFR. The link provided in the DHS press release did not work. I ended up doing a search of the Federal Register to find it. Fortunately, with the tools available on the Internet (see: http://www.gpoaccess.gov/fr/search.html) that wasn’t much of an undertaking.

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