Importer Security Filings (ISF) preparation
To underline the significance of the ten (10) ISF data elements (excluding the "phantom eleventh"), I highly suggest you to amend your purchase order or other contractual agreements used in the transaction to require the vendor or supplier to comply with Importer Security Filing standards. Some importers are also imposing conditions on financial instruments like letters of credit. Including such language in your contract documents could be a mitigating factor if CBP fines you for late or inaccurate reporting after January 2010.
I also propose that you contact your participating ocean carriers, NVOCCs, and freight forwarders and carefully coordinate operations with them. Meetings should be held ahead of time between your supplier base and the carrier(s) at origin to iron out new protocols and techniques for issuing the bill of lading number. Because most major ocean carriers (Maersk, APL/NOL, Evergreen, Hanjin, NYK, K-Line, OOCL, and others) are well-versed in ISF, their overseas offices can assist you in educating your vendor and supplier network if appropriately leveraged. I recommend contacting your carrier's US agent and demanding that their international offices engage problematic vendors or assist you in communicating this new requirement.
Several importers are enforcing vendor penalties as part of their vendor compliance procedures to encourage compliance and help offset the potential cost of CBP penalties filed against the importer.
Tips for Notifying Your Vendors and Suppliers
Importers are currently concerned about their ability to obtain a bill of lading number in advance, as well as a lack of cooperation from suppliers and vendors. If you decide to file your ISF directly, look for a provider that has produced recommended notifications to send to suppliers and vendors. Recommended reading or attachments to your correspondence include an Adobe copy of the CBP Interim Final Rule (Federal Register Notice), copies of your new company policies or methods, copies of other publications concerning Importer Security Filing, and/or letters from Senior Management emphasizing the importance and their support for the initiative.
Companies that use paper-based traceability procedures may under significant strain if they are asked to provide correct and updated records with only 24 hours' notice. They'd have to track down the documents, double-check them for accuracy, and then put them into a searchable spreadsheet with only the needed data – all in around 24 hours. Park City Group co-founded ReposiTrak Inc. with Leavitt Partners, chaired by Michael Leavitt, former Secretary of Health and Human Services, to meet the predicted surge in regulatory requirements connected with the Food Safety Modernization Act of 2011. (FSMA).
All of this can be done in a matter of seconds with SafetyChain. An easy-to-use dashboard allows you to search for records by product type, date, line, lot, and other criteria. These personalized reports are simple to share, so you may send them to as many people as you choose. You can also set up controls to guarantee that data is collected consistently and shared with just the people who need to know.
Exceptions to the rules
Small farms that sell linear to the public, small retail food enterprises, and nonprofit food establishments are among those that are excused from the proposed Food Traceability Rule. A complete list of exemptions can be seen on the FDA's website.
FDA traceability requirements compliance date proposed
The FDA has recommended a two-year compliance date following the final regulation, and unlike many previous laws, there will be no phase-in period based on the size of the business. By the same deadline, everyone involved must comply.
Meanwhile, the public comment period will run until January 21, 2021, and a series of virtual meetings to examine the proposed regulation will be held in November and December 2020.
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