Per CSMS #14-000637, US Customs is eliminating the late ISF submission exemption from bond requirements:
“Effective January 10, 2015, late ISF submissions will no longer be exempt from the bond requirement and most ISF transactions will require a bond when they are filed. To avoid delay or examination upon arrival, importers should ensure that bonds are in place to cover the ISF transaction prior to the cargo being loaded on the vessel destined for the United States.”
While this particular ISF bond exemption is going by the wayside (remaining are those for household goods, government and military, informal shipments and a handful of others), the impact on the trade will be insignificant.
First, as a practical matter, most importers already secure a single ISF transaction bond (or use an existing continuous bond) in these instances. Moreover, CBP’s eBond functionality, schedule to debut on January 3, 2015, will begin to render the current single transaction bond procurement process moot, as e-Bond will allow for instantaneous filing and approval of bonds for importers who do not have one in place already. Specifically, on that date:
For ACE Entries followed by ACE Entry Summaries, or ACE Entry Summaries certified for ACE Cargo Release, where a Single Transaction Bond is used, an eBond will be required. ACE will implement validations on these inbound transactions where, if a bond is referenced on a transaction, and no bond is found on file in ACE, that transaction will be rejected.
For all other single transaction bond scenarios listed above utilizing the legacy ACS system, eBond will not be required. CBP will continue the paper processing of these bonds until ACS is retired and supplanted by ACE for all transactions in October 2016. For more information, see US Customs’ November 2014 presentation, “e-Bond: The Future of Bonds in ACE.”