AMERICAS: US importers/exporters concerned over 10+2

The American Association of Exporters and Importers (AAEI) has expressed concern to US Customs and Border Protection (CBP) that the costs of complying with the Interim Final Rule on Importer Security Filing (ISF), also known as ‘10+2’, were unclear and will likely be much higher than currently anticipated. The 10+2 rule requires cargo information, for […]


The American Association of Exporters and Importers (AAEI) has expressed concern to US Customs and Border Protection (CBP) that the costs of complying with the Interim Final Rule on Importer Security Filing (ISF), also known as ‘10+2’, were unclear and will likely be much higher than currently anticipated.

The 10+2 rule requires cargo information, for security purposes, to be transmitted to CBP agents at least 24 hours before goods are shipped to the US. “In the first months of implementation, the only cost CBP is capturing is the transaction fee for filing,” said the AAEI.

“However, AAEI notes that the true costs are much higher, especially for small and medium-sized enterprises. Plus, hidden costs of 10+2 compliance will add up quickly due to delays and slowdowns in the supply chain.”

The AAEI said it was also concerned about “the lack of tangible benefits for voluntary participation in the costly CTPAT programme” and recommended that CBP allowed C-TPAT members to satisfy 10+2 requirements by providing routine data at the aggregate level for common shipments.

AAEI General Counsel (Interim Executive) Marianne Rowden added: “We are collecting information from our members as they experience the first stages of 10+2 and we urge CBP to re-evaluate the programme before it goes forward with its plan to begin full enforcement on January 26 next year.”