40 Trade Groups Urge Prototype of 10+2 SF Prior to Final Rule
Forty trade groups1 have signed a letter urging Congress to request that U.S. Customs and Border Protection conduct a prototype program on its "10+2" rulemaking prior to the issuance of a final rule.
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(In January 2008, CBP issued its proposed rule to require Security Filing (SF) information from importers and additional information from carriers (10+2) for vessel (maritime) cargo before it is brought into the U.S.)
Groups Warn 10+2 Could Raise Cost of Doing Business, Create New Threat
The trade groups warn that implementing CBP's rulemaking, as presently drafted, will significantly raise the cost of doing business at a time when increasing global competition and a slowing domestic economy are creating new stresses on U.S.-based businesses and companies from every sector.
The groups note that many U.S. companies believe that the 10+2 proposed rule creates new security threats by greatly increasing the opportunity for their containers to be tampered with while sitting for an additional two to five days at a foreign port awaiting export because of the additional time required for importers to collect and submit the new data that would be required by 10+2.
Prototype is Best Method for Evaluating 10+2's Impact on Security, Business
The trade groups believe that a prototype would be the best method for evaluating the proposed rule's impact on both security and business as well as for identifying ways to improve the rule before the government and industry invest billions of dollars in its implementation.
1The forty trade groups that signed the letter to Congress are:
The Adhesive and Sealant Council, Inc.
AeA (formerly American Electronics Association)
Air Movement & Control Association International, Inc.
Alliance of Automobile Manufacturers
American Apparel & Footwear Association (AAFA)
American Architectural Manufacturers Association
American Association of Exporters and Importers
American Petroleum Institute
The Association for Hose & Accessories Distribution (NAHAD)
The Association For Manufacturing Technology (AMT)
The Association for Suppliers of Printing, Publishing and Converting Technologies (NPES)
Association of International Automobile Manufacturers, Inc.
Association of the Nonwoven Fabrics Industry (INDA)
Automotive Trade Policy Council
Coalition for Employment Through Exports
Computing Technology Industry Association (CompTIA)
Consumer Electronics Association
Consumer Healthcare Products Association
CropLife America
Distilled Spirits Council of the U.S.
Emergency Committee for American Trade (ECAT)
European-American Business Council
Foreign Trade Association of Southern California
Industrial Fasteners Institute
Information Technology Association of America
Information Technology Industry Council (ITI)
International Housewares Association
Joint Industry Group
Metal Treating Institute
Motor & Equipment Manufacturers Association (MEMA)
National Association of Manufacturers (NAM)
National Foreign Trade Council
National Marine Manufacturers Association
Responsible Industry for a Sound Environment (RISE)
Salt Institute
Secondary Materials and Recycled Textiles Association (SMART)
Telecommunications Industry Association
Travel Goods Association (TGA)
U.S. Business Alliance for Customs Modernization (BACM)
U.S. Chamber of Commerce
(See ITT's Online Archives or 01/17/08 news, 08011710, for the final part of BP's summary of the 10+2 proposed rule, with links to previous parts.
See ITT's Online Archives or 06/20/08 news, 08062010, for BP summary of the NAM's request for real world testing of 10+2 before implementation.)
Trade group letter to Congress available at http://www.nam.org/hidden/pdf/Association_Letter_on_102Rule.pdf.
NAM press release on trade group letter (08-159, dated 07/17/08) available at http://www.nam.org/s_nam/doc1.asp?TrackID=&SID=1&DID=240746&CID=46&VID=2&RTID=0&CIDQS=&Taxonomy=False&specialSearch=False.