CBP Discusses its Importer Self-Assessment Program at Trade Symposium
At the December 2009 Trade Symposium, Customs officials and importer and broker representatives discussed the Importer Self Assessment program.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
(ISA is a voluntary approach to trade compliance. The program provides the opportunity for importers who have made a commitment of resources to assume responsibility for monitoring their own compliance in exchange for certain benefits.)
Highlights of those discussions include:
ISA Program Currently Has 198 Participants, Over 99% Compliance Rate
During the presentation, CBP provided the following statistics regarding ISA participants:
- 198 participants (820 different Importers of Record (IOR))
- ISA participants were 99.28% compliant in FY 2008
- In FY 2008, ISA participants represented approximately 16% of the total value imported and over 15% of the revenue paid
- ISA participants had only 0.44% of the revenue gap (FY 2008)
- CBP has denied 18 ISA applicants
- 47 ISA applicants are under an improvement plan
- 20 members have withdrawn from ISA
ISA Benefits Include Fewer Audits, Penalty Mitigation, Enhanced Prior Disclosure
CBP states that ISA benefits include:
- Exemption from comprehensive audits (Regulatory Audit)
-Focused Assessments
-Drawback and Foreign Trade Zone audits
- Less Customs intrusion
-Participants can see reduced cargo examinations, fewer document inspections (e.g., CBP Forms 28, 29), quicker clearance, and fewer rejects
- Coverage available for multiple business units
- Greater business certainty
-More accurate data
-Company control over the process
- Consideration as a mitigating factor in penalty or liquidated damages
- Additional industry-specific tailored benefits
- Enhanced Prior Disclosure benefits
ISA Application Problems Include Incompleteness, Multiple IOR Nos, Unresolved Issues, Etc.
According to CBP, problems with the ISA applications it has received include:
- Incomplete application
- C-TPAT and ISA applications for different companies
- Including multiple IOR numbers on one ISA application, when many and/or all of the IOR numbers pertained to divisions with differing procedures
Top Countries of Origin for ISA Applicant Imports are China, Mexico, and Japan
According to CBP, for 65 of the 252 of the applicants to the ISA program, China is the top country of origin for their imports. Mexico is the top country of origin for 28 of the 252 ISA applicants, and Japan is the top country of origin for 22 of the 252 ISA applicants.
CBP Discusses New "I-3" ISA Review Process
At the Trade Symposium, CBP discussed an ISA review process for periodically monitoring participants in the ISA program which it is calling "I-3." CBP will be able to pick the company to review. or a company can volunteer for such a review. CBP is working on developing a PowerPoint presentation on its I-3 review process, which will be posted to the CBP Web site.
CBP Trade Symposium ISA PowerPoint presentation available at http://www.cbp.gov/linkhandler/cgov/trade/trade_outreach/presentations09/isa_present.ctt/isa_present.pdf.
BP Note
According to an article in the January 8, 2010 Customs Overview issued by the U.S. Association of Importers of Textiles and Apparel (USA-ITA), two of the reasons that textile and apparel importers may have not participated in ISA no longer exist. The article states that there is no longer a specific Memorandum of Understanding for textile and apparel importers and there is no matrix (which USA-ITA states listed various undertakings such as agreeing to drop a supplier which had a shipment excluded after a review of production documents). CBP sources have confirmed that these documents are no longer being used.