**Trade Support Network Supply Chain Security Committee**

**Questions/Comments From Trade Representatives**

**[Questions/Comments Group 1]{.underline}**

**A. Update of ISF - The regulations require the filer to update the ISF
if any of the information changes or more accurate information becomes
available.**

1\. Does CBP envision a full ISF replace or can the changes alone be
submitted?

2\. What if the change requires the addition of new lines? For example,
the importer determines that a different HTSUS number must be reported
and due to the linking requirement new lines must be created, how would
the filer accomplish this? Suppose the opposite occurs and lines must be
deleted?

3\. Will the filer receive an electronic acknowledgment for changes and
updates?

4\. Importers and filers would like visibility to change records
associated with each change or update.

**B. Diversion - Permission to divert an in-bond movement to a port
other than the listed port of destination or export or change the
in-bond entry into a consumption entry must be obtained from the port
director of the port of origin.**

1\. Please identify the data sets to be used for this purpose.

2\. What type of acknowledgment will be received?

3\. How will permission be indicated/transmitted?

4\. Importers and filers would like visibility to records associated
with diversion.

**C. Do Not Load Messages**

1\. Will a message go to both the ISF filer and the carrier?

2\. What will the message look like? What information about examination
location and time will be contained in it?

3\. After examination, what messages will the filer receive to indicate
the the shipment/containers have been released for loading?

4\. If container number is provided will CBP likely limit exams/holds to
the related container versus all containers on the bill of lading?

5\. What, if anything, is required if an ISF has been sent and the
container is not loaded?

**D. Queries**

1\. Will ISF data be loaded into ACE so that queries and reports can be
run?

**E. Regarding the data elements for FROB, IE and T&E:**

1\. The requirements call for a Ship-To and Place of Delivery (city
code). What city codes are we supposed to use? Will CBP publish these?

2\. Given that Ship-To contains a city address component, this
requirement seems redundant. What is CBP looking for?

3\. Since Country of Origin is not a requirement, will CBP allow
Importers to provide just a list of unique HTS# that apply to a specific
entry? In other words, can we just provide header level data?

**[Questions/Comments Group 2]{.underline}**

**Isf_25_catair.doc -- Application SF**

1\. If there are multiple manufacturers for one security filing are the
tariff numbers (SF40) for one manufacturer grouped under the
manufacturer (SF30, SF35 and SF36) or does the manufacturer repeated for
each SF40?

2\. The ISF-10 LOOP DEFINITIONS section is confusing. It seems like all
parties are reported for the ISF and then the manufacturer is repeated
with the SF40 and not the entire SF30-SF36 repeated for each SF40.

Seems like it should be more like this:

For all parties except MFG

SF30

SF31

SF35

SF36

For MFG

SF30

SF31

SF35

SF36

SF40

3\. If there are multiple master/house bills for the ISF are these
reported by repeating the SF15 records?

Ex SF15 with Master

SF15 with House

SF15 with 2nd Master

SF15 with 2nd House etc.

4\. Will the 50 character Master/House bill be used at this time or will
it only be implemented with Cargo Release with ACE?

5\. Why does the SF20 have the Master bill as an option? It seems like
these should have been reported on the SF15.

**Cargo Release - HI**

6\. Why is the SF30 different than what the SF30 is in the Application
SF? The one in Application SF makes more sense.

**[Questions/Comments Group 3]{.underline}**

1\. Besides ABI MQ, will there be any other means of submitting the ISF
data such as FTP?

2\. If the broker submits combined ISF (embedded with the Cargo Release
or Entry Summary)

a\) What will be the procedure to correct the ISF and/or entry data if
needed? i.e. ISF is correct, but entry data is not and vice-versa.

\- will they have to delete both, will they lose paperless status if the
ISF is changed and everything is re-submitted, etc.

b\) The entity type for Manufacturer is MF, but they make numerous
references to CM. What is the difference between the two?

c\) The use of the address qualifier will be an onerous task. Are these
record layouts finalized?

**[Questions/Comments Group 4]{.underline}**

**In the ISF Formats posted in draft on the CBP site, some allow use of
DUNS and some do not.**

1\. When an entity is being identified by Name and Address, why not
permit inclusion of DUNS in all messages from all filers?

2\. Will CBP allow a filer to include only a DUNS in lieu of Name and
Address when the DUNS is established for that entity at that location?

**[Questions/Comments Group 5]{.underline}**

1\. What is CBP's intention regarding reporting the MID in the SF30,
positions 46-65? The NPRM comment and response says the MID will not be
accepted, but the SF35 says it will.  If it will, then the SF30
description needs to include the CM as well as the CN as acceptable
records in positions 46-65.  If not, then SF35 should be rewritten so as
to not reference the CM for that purpose.

**[Questions/Comments Group 6]{.underline}**

+--------------+-------------------------------------+-----------------+
| RECORD       | QUESTION                            | ADDITIONAL      |
|              |                                     | COMMENTS        |
+==============+=====================================+=================+
| SF10         | What is the key data (BL, HBL, IOR) | Does the record |
|              | that will be used to start a new    | break on BL,    |
|              | ISF file?                           | HBL, IOR?       |
+--------------+-------------------------------------+-----------------+
| SF10         | If a data element is                | The file must   |
|              | changed/updated, then does a        | have all the    |
|              | complete replacement SFI need to be | information not |
|              | submitted?                          | just the        |
|              |                                     | information     |
|              | If a file is corrected based upon   | that changed.   |
|              | the SF90 record information, should |                 |
|              | fixed ISF be submitted as a         |                 |
|              | replacement or as a new file?       |                 |
+--------------+-------------------------------------+-----------------+
| SF10         | Date of Birth Status=M; Shouldn't   | M implies its   |
|              | this be a Conditional requirement   | mandatory at    |
|              | if AEF qualifier is used.           | all times.      |
+--------------+-------------------------------------+-----------------+
| SF10         | Mode of Transportation=an ocean     |                 |
|              | vessel could be both                |                 |
|              | non-containerized and containerized |                 |
|              | so what qualifier should be used.   |                 |
|              | Is it expected that the filer needs |                 |
|              | to ask the carrier the vessel type? |                 |
+--------------+-------------------------------------+-----------------+
| SF15 and     | Does CBP want both the HBL and MBL? |                 |
| SF20         | If so, which one comes first and    |                 |
|              | does the first one go in the SF15   |                 |
|              | and the next record go into SF20    |                 |
|              | (for example, SF15 has BL and SF20  |                 |
|              | has HBL)                            |                 |
+--------------+-------------------------------------+-----------------+
| SF35         | Address Information: Status='M'     |                 |
|              | shouldn't it be C since it based if |                 |
|              | Address Component Qualifier is      |                 |
|              | present?                            |                 |
+--------------+-------------------------------------+-----------------+
| SF35         | Qualifier 01 Street Number: Does    |                 |
|              | CBP actually want the filer to      |                 |
|              | separate the street number from the |                 |
|              | street name?                        |                 |
+--------------+-------------------------------------+-----------------+
| SF36         | Country Sub Entity Code: Is this    |                 |
|              | field long enough (9 characters) to |                 |
|              | fit a foreign province name?        |                 |
+--------------+-------------------------------------+-----------------+
| SF50         | Code Qualifier of K or UN; What     |                 |
|              | happens if a location does not have |                 |
|              | a Schedule K or UN Loc Code?        |                 |
+--------------+-------------------------------------+-----------------+
| SF90         | What is the timeframe this record   |                 |
|              | will be returned---hours, minutes   |                 |
|              | after receipt of the ISF? Does this |                 |
|              | record fulfill the 'acknowledgment' |                 |
|              | requirement that CBP was expected   |                 |
|              | to provide to the filer or is there |                 |
|              | another type of acknowledgment that |                 |
|              | CBP will return initially?          |                 |
+--------------+-------------------------------------+-----------------+

**[Questions/Comments Group 7]{.underline}**

+-----------+----------+-----------------------------------------------+
| > Data    | > SF     | How will CBP create and manage new            |
| >         | >        | Importer/Consignee Numbers?                   |
|  Elements | Importer |                                               |
|           | > Tran   |                                               |
|           | smission |                                               |
+-----------+----------+-----------------------------------------------+
| > Tra     | > SF     | Regarding the SF90 Output(CBP transmission to |
| nsmission | > reply  | filer), will both the Carrier and Broker      |
|           |          | receive this output file?                     |
+-----------+----------+-----------------------------------------------+
| > Tra     | > SF     | CAMIR Appendix H shows only 6 valid error     |
| nsmission | > reply  | codes for the SF90 Record Identifier (#364    |
|           |          | -369). Is this a complete list of possible    |
|           |          | error messages?                               |
+-----------+----------+-----------------------------------------------+
| > Tra     | > SF     | What is the significance of message           |
| nsmission | > reply  | \"Accepted with Warning\"? Will the importer  |
|           |          | have to take specific actions for future      |
|           |          | transmissions or will they be required to     |
|           |          | resubmit a revised SF transmission?           |
+-----------+----------+-----------------------------------------------+
| > Data    | > SF     | Optional Container Number - What are the      |
| >         | >        | advantages to submit Container Number? If no  |
|  Elements | Importer | container number is transmitted is it         |
|           | > Tran   | possible that the entire MBL will be placed   |
|           | smission | on hold?                                      |
+-----------+----------+-----------------------------------------------+
| > Tra     | > SF     | How long can an Importer expect to wait to    |
| nsmission | > reply  | receive a SF message back from CBP? (Initial  |
|           |          | transmission, Changes, deletions)             |
+-----------+----------+-----------------------------------------------+
| > Tra     | > SF     | If a container at the foreign port receives a |
| nsmission | > reply  | load clearance on ISF transmission but does   |
|           |          | not receive local customs export clearance    |
|           |          | and will not be able to make the vessel, will |
|           |          | a revised ISF be required?                    |
+-----------+----------+-----------------------------------------------+
| > Data    | > SF     | DUNS Number registration - How is this done   |
| >         | >        | and what is the timeframe to complete a       |
|  Elements | Importer | registration request?                         |
|           | > Tran   |                                               |
|           | smission |                                               |
+-----------+----------+-----------------------------------------------+
| > Tra     | >        | Typically FTZ shipments are assigned while    |
| nsmission | FROB/FTZ | the cargo is en route on the vessel. This     |
|           |          | means that cancellation of our initial ISF    |
|           |          | for replacement with a FROB ISF will be a     |
|           |          | regular occurrence. How will this impact our  |
|           |          | importer standing with CBP and will this lead |
|           |          | to additional scrutiny. The point here is     |
|           |          | that the re-transmission is not because of    |
|           |          | incorrect information; it is a result of our  |
|           |          | current business process.                     |
+-----------+----------+-----------------------------------------------+
| > Data    | > SF     | Currently the majority of ocean carriers      |
| >         | >        | issue their MBL on or very close to the date  |
|  Elements | Importer | of sailing from the foreign port. Will CBP    |
|           | > Tran   | require that the ocean carriers modify this   |
|           | smission | practice in order to make the MBL# available  |
|           |          | earlier for Importers to include in their ISF |
|           |          | transmissions?                                |
+-----------+----------+-----------------------------------------------+
| > Tra     | > SF     | Will the error codes also be transmitted when |
| nsmission | > reply  | an \"Accepted with Warning\" message is       |
|           |          | transmitted from CBP?                         |
+-----------+----------+-----------------------------------------------+

**[Questions/Comments Group 8]{.underline}**

1\. It is suggested that the option to provide the Importer Security
Filing data elements in advance on an account basis should be provided
in the technical data. Several Trade Representatives of the TSN Supply
Chain Security Committee are willing to work with CBP on this
initiative.

2\. It is also suggested that CBP engage the TSN to work on the
technical requirements needed for improved functionality in the ACE
environment.

3\. As discussed by CBP we suggest that a link be developed in the
targeting system checking the C-TPAT status of the IOR# and if in C-TPAT
the likelihood of inspection be lowered relative to the C-TPAT Tier
status.

**[Questions/Comments Group 9]{.underline}**

1\. How do we layer HTS

A. Within a supplier within a container and within a bill of lading?

1\. For a stand alone filing?

2\. When multiple consignees or consolidators or packing facilities are
used?

**[Questions/Comments Group 10]{.underline}**

**Specifications:**

1\. In the SF90 specification, the description of Position 7,9 is that
it is a code that \"qualifies\" the narrative message, which we assume
is the text in position 10,49. Because we normally would expect the two
positions to be directly related (for a given code, the text would
always be the same), we do not understand what CBP means by saying the
code \"qualifies\" the narrative message.

**ISF Retransmission and Correction:**

1\. What are the implications or restrictions on resubmissions of a
combined ISF and entry summary? For example, if a filer needs to amend
the entry summary data, may a filer submit a combined transmission even
though there is no change to any of the ISF data?

2\. What is the effect of an update or retransmission of an ISF? Will
the system accept retransmissions without causing problems for CBP or
affecting the shipment status, for example would the fact of a
retransmission by itself cause loss of paperless status or raise some
sort of red flag?

3\. Does a retransmission delete the original ISF? If so, would a
retransmission made subsequent to the expiration of the 24 hour prior to
loading time limit, cause the system to show the ISF had been filed late
and be noncompliant? If that is the case, how should updates be made so
as to avoid having the ISF be considered late?

4\. How will the system determine the cut-off point for receiving ISF
updates on a shipment? The NPRM specified updates will be allowed until
port arrival. Will the estimated time of arrival (ETA) be used to as the
port arrival date or will CBP use data from another source for that
determination?

**ISF Acceptance and Rejection:**

1\. Will the system reject an ISF only for data processing type errors
such as incorrect syntax, code or BL or SCAC format, or will there be
rejections for other reasons such as an importer or seller being on the
National Sanction List or an excluded party list?

2\. What is an example of a warning message that would be used when an
ISF is accepted with warnings? Will CBP put out a list of the warning
messages and a list of the actions required for each one?

3\. What should filers use as the date and time of ISF acceptance and
how will CBP indicate it?