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USCBPRulemakingUSCBP-2007-0077

Importer Security Filing and Additional Carrier Requirements

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American Apparel & Footwear Association filings
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American Apparel & Footwear Association filed 1 comment on this docket between Mar 20, 2008 and Mar 20, 2008. 92 other organizations filed here. The comment window closed 6266d ago.

What American Apparel & Footwear Association filed (1)

Mar 20, 2008· Comment Submitted by Kevin M. Burke, American Apparel & Footwear Association· USCBP-2007-0077-0162

March 18, 2008 Border Security Regulations Branch Office of Trade U.S. Customs and Border Protection 1300 Pennsylvania Avenue, NW (Mint Annex) Washington, DC 20229 REF: Notice of Proposed Rulemaking (NPRM), Importer Security Filing (ISF) and Additional Carrier Requirements (73 Federal Register 90). Docket Number: USCBP-2007-0077 To Whom It May Concern: On behalf of the American Apparel & Footwear Association ? the national trade association of the apparel and footwear industries ? I am writing to offer comments on the Department of Homeland Security (DHS) Customs and Border Protection (CBP) proposal regarding Importer Security Filing and Additional Carrier Requirements (the so-called ?10+2 proposal?). We appreciate the opportunity to submit comments on this matter. AAFA members make, manufacture, and sell garments, shoes, and accessories ? and their inputs ? throughout the United States and around the world. Because clothing and footwear are so heavily traded, our members have considerable experience dealing with customs and various supply chain issues. At the outset, we wish to stress our strong commitment to ensuring the protection of the nation?s cargo systems and the security of our members? supply chains. Our members include some of the earliest and most active supporters of the Customs Trade Partnership Against Terrorism (C-TPAT). Notwithstanding this strong commitment to the nation?s security, our members have expressed very strong concerns regarding the current format of the 10+2 proposal. We urge that these concerns be addressed and resolved before DHS and CBP move forward on this important work. Principle concerns cited by our members include: Excessive penalties: We believe the NPRM contains excessive fines that are punitive and unnecessary. Currently, the proposal calls for penalties that equal the value of the goods to an importer who does not file an ISF. We do not understand why this is necessary since failure to file an ISF would, in theory, result in a ?do not load? order, which will prevent a good being shipped to the United States. Issuing a fine on top of that order seems punitive and entirely unnecessary. Similarly, we are concerned that huge penalties (as much as $5000 per error) could be imposed on companies making simple clerical errors or honest mistakes trying to interpret these rules. Inaccurate Cost Estimates: Many of our member companies have already incurred significant costs to build additional security into the supply chains so they can achieve C-TPAT status or to comply with other security rules, such as the 24 hour rule. The proposed rule envisions additional costs and burdens, which we believe are understated in the Federal Register notice. Members have cited a range of costs including those related to delays in cargo, added compliance, additional paperwork, and increased burdens. Accordingly, we respectfully encourage DHS and CBP to work with the Office of Management and Budget to generate more accurate estimates in order to ensure a fuller cost-benefit analysis before further work can be completed on the proposed rule. Duplicate data collection, especially for C-TPAT companies. We notice that the proposed rule involves the reporting of information which is currently being reported, although the timing of that data collection is different. While we understand that this increased data flow is intended to help identify risky shipments, we note further that this demand is also imposed on companies whose supply chains have already been validated under C-TPAT. While the ISF may help better identify riskier shipments in the supply chains of companies who have not yet signed up for or been validated under C-TPAT, it strikes us as unnecessary and duplicative to impose those identical ISF requirements on validated C-TPAT companies. Account vs. ?Shipment by Shipment? Security: On a similar note, we are concerned that the overall approach symbol…

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