US Customs recently announced, in CSMS #15-000275, the implementation of the Broker-Known Importer Program (BKIP), an initiative proposed by the National Customs Brokers & Forwarders Association of America (NCBFFA).
The program allows a licensed customs broker to inform CBP, via the filing of an electronic entry, that the importer listed on the entry is known to the broker, and that the broker has advised the importer of their compliance responsibilities under Customs regulations. In addition, the broker will have verified the importer’s grasp of its obligations in areas such as entry declarations, ADD/CVD, IPR, valuation and preference programs, through a questionnaire.
CBP will use this information for purposes of cargo risk segmentation. When a broker identifies an importer who is exercising reasonable care in connection with their imports by checking the BKIP indicator flag on an entry, Customs may adjust that importer’s risk profile in CBP’s targeting system accordingly, even if the importer is not part of the Trusted Trader programs — C-TPAT or ISA. (The BKIP indicator flag for entries has already been deployed as part of ACE.)
BKIP is a voluntary program for both brokers and importers.
- New platform for brokers and importers to discuss compliance obligations
- Potential to increase broker entry accuracy
- Increased compliance knowledge for importer staff
- Improved cargo targeting by CBP at time of cargo arrival
- More information to CBP about importer from a trusted source
It’s been almost three months since the labor dispute that crippled US West Coast ports was tentatively settled, and since then, containerized imports are on the upswing.
According to the Journal of Commerce*, the National Retail Federation in its publication, Port Tracker, reported that March import traffic jumped 45% from February, when the discord between the International Longshore and Warehouse Union and Pacific Maritime Association severely hampered port operations for several months.
Dockworkers and management have made a concerted effort clear the massive container backlog resulting from the port slowdowns (presumably, in part, due to the implementation of chassis pools), although the ILWU has yet to ratify February’s agreement on the dockworkers’ labor contract (vote due on May 22).
See also our previous blog post: Most shippers to divert cargo away from US West Coast ports.
(*JOC site registration required)
Looking for additional headcount in your trade compliance group but are afraid to ask? Don’t be. Matt Beck, author of the Ask The Trade Compliance Manager Blog, opines that even though adding new employees is a tricky subject in many companies, it’s better to make a thoughtful case than to never ask at all.
Among other things, Beck suggests:
“In making the case, above all you need to show the decision-makers that you have done all of the necessary analysis and that you are extremely certain that you absolutely need a new person. Show how the current situation is inadequate, particularly through increased risk or hemorrhaging money. Back up your assertion with hard numbers (duty savings, export license application times, etc.) if you can. Paint a picture of what your department would look like with a new person on-board including what their job responsibilities will be, how current employees’ job responsibilities will change and what will happen once this person is on-board to justify cost of having them.”
As for increasing import staff in particular, in a previous blog post, CustomsNow™ outlined additional considerations, such as:
- Import volume
- Complexity of entries
- Involvement of PGAs
- Whether an LCB license is required
- Whether an importer is direct filing its own entries and ISFs
As to the latter point, and critical to the headcount discussion, direct filers often do not require additional staff to roll out a self-filing program. We have found that most average sized importers have sufficient resources on staff to implement the initial direct filing process. Additional staffing may be necessary, however, as savings are generated and the direct filing programs expands further.