What is CBP's 10 + 2 Data Elements Proposal?

With the pasage of the SAFE Port Act of 2006 Congress has mandated that the Customs and Border Protection agency (CBP) gather additonal data elements about every import before the shipment is made. The import community is to provide ten data elements while the ocean carriers are to provide two. This reporting would supplement what CBP already receives from ocean carriers twenty four hours in advance of shipment from foreign ports. Below are links to .pdfs further explaining 10 + 2.

While the regulation is being developed, sent out for comment and reworked it will be a very short year before it's in effect. Our position is that the regulation is inevitable and yet the import community will find it very hard to comply with. "10 + 2" may be the watershed moment for companies to rewrite their methods and processes for imports instead of trying to patch old and costly traditions.

The second .pdf linked above on page 5 has the following from CBP. "Because of the similarity of the ten data elements of the Security Filing and entry data, importers may be interested in fulfilling both Security Filing and entry obligations at the same time by filing 24 hours before vessel loading."

We have been practicing filing our entry summary before shipment has left the overseas port for several years now! This 10 + 2 regulation will cause us absolutely no bother at all. It was possible for us to make early entries because we integrated the various data elements required for a early declaration into a single enterprise database system. The "Do it Sooner" import process we developed takes its inspiraton from the Japanese "just in time" manufacturing methods described in the book, "The Machine That Changed the World : The Story of Lean Production" by James P. Womack, Daniel T. Jones and Daniel Roos. The advantages of our process is that it's lean and adaptable. The economy derived comes from thinking about the elements of a successful importation beforehand and not afterward when a crisis develops.

We are available to consult on our "Do it Sooner" process. Please use the information on the left panel to contact us. We believe that CBP's move to implement "10 + 2" gives the import community an opportunity to streamline their operations and thereby reduce costs. The Congressional Budget Office's report on this regulation should be that it saves you money while augmenting the nation's security.

This page was last modified 4 September 2008