What are the major benefits of an importer filing his own entries?
Which customs
entries can I clear myself?
Are there
upfront fees or contracts required to participate?
How is TRG
Direct direct-filing different from other direct-filing programs?
How long does
it take to get set up to file our own entries?
What are CBP’s requirements for direct-filing?
What is the testing with CBP on the ABI system prior to being approved?
Must I discontinue using my present broker?
How do we get started with TRG Direct®?
How does TRG Direct® assist the importer who wishes to direct-file?
Do I need to give TBI Brokers (TBIB) a Power of Attorney (POA)?
How are duties paid for entries I’ve filed myself?
Am I required to establish an importer direct-audit process?
What if I decide that I no longer want to clear my own shipments?
Are there any entries that I can’t clear using direct-filing?
Am I able to direct-file Canada & Mexico border entries?
How do I clear entries requiring release by the Food & Drug Administration (FDA)?
How do I file the Prior Notice for FDA goods?
What if I need help clearing my shipment?
Once cleared, how do I arrange delivery of my shipment?
How do I handle CBP or PGA exams of my shipments?
What are the recordkeeping requirements for entries that are direct-filed?
Are there any additional compliance requirements when direct-filing?
Direct-Filing FAQ's
What technology does TRG Direct® use to file the entries with Customs?
How is the importer's data stored and backed-up?
Once I file an entry, how do I understand the feedback and results I get back from the CBP via the ABI system?
Can I access my importer data at any time?
Is there a place on the system to store my “Parts” information, and can it be updated electronically?
How do I arrange payment for services of 3rd party vendors such as, CBP exam sites?
I have several different product codes/SKUs which are the same tariff number on one commercial invoice. Do I have to enter each invoice line separately, or can I combine them together?
Importer Security Filing FAQs
Why am I getting a “Duplicate” file message?
Do rollover shipments need new ISFs?
What is an AMS Bill of Lading?
Why haven’t I received a response from Customs after filing an ISF?
Can I file my ISF early?
What is an invalid transaction error?
Definitions of the Entities (Data Elements).
What are the different ISF transaction types?
How can I possibly get the Bill of Lading Number on time?
I have done everything I could to transmit a compliant ISF, but was still unable to do so. How do I let Customs know I tried?
Terms and Definitions
What is importer direct-filing of customs entries or direct-filing?
What is Remote Location Filing (RLF)?
What is a Filer Code?
What does Automated Broker Interface (ABI) mean?
What is Automated Clearing House (ACH)?
What is ACE?
What is Periodic Monthly Statement (PMS)?
What is “Electronic Invoice Processing” (EIP)?
What are the major benefits of
an importer filing his own entries?
Direct-filing gives an importer greater control over the import process, his
supply chain (which can result in lower costs), more consistent compliance, less
risk of non-compliance and a lower cost per entry.
Which customs entries can I
clear myself?
Formal entries (type “01”) and informal entries (type “02”) for both air and
ocean shipments, may be filed using the Remote Location Filing (RLF) / Automated
Invoice Interface (AII) program.
Are there upfront fees or
contracts required to participate?
There are no long-term contracts to sign. There is a $2,500 non-refundable set-up fee required for Customs entry filing only. There is no set-up fee required for importers to engage us for Importer Security Filing.
How is TRG Direct®
direct-filing different from other direct-filing programs?
TRG Direct® is accessible to small and medium sized importers because it does not
require a large investment in software or hardware. TRG Direct® is more than
importer direct-filing of customs entries. The TRG Direct® program includes the
support of a nationally licensed customs broker, TBI Brokers, Inc. on an
as-needed basis. The direct-filer gets the benefit of lower entry costs without
giving up access to a licensed customs broker.
How long does it take to get
set up to file our own entries?
This depends on the importer’s commitment to set-up. To begin self-filing Customs entries, the entire process usually takes between 6-8 weeks. To begin use of TRG Direct® for Importer Security Filing, this only takes 1 – 2 days.
What are CBP’s requirements for direct-filing?
Assignment of a Filer Code from CBP.
Submission of an ABI Letter of Intent.
Assignment of an ABI Representative.
Complete a simple “ABI Test” from CBP.
Pay duties and taxes via “ACH”, or ACE “Periodic Monthly Statement” (PMS).
Electronic transmission of commercial invoices to CBP.
Approval by CBP to file entries via RLF.
What is the testing with CBP on the ABI system prior to being approved?
CBP requires that all filers transmit certain test entry data (as specified by CBP) in order to ensure that the ABI system can handle any special entry requirement. In addition, the importer is required to transmit five electronic invoices in test mode. Once these “tests” are completed, the filer is ABI approved.
Must I discontinue using my present broker?
No. In fact the TRG Direct® direct-filing service is designed to serve as an “add on” service. Direct-filing is intended to allow importers to reduce costs of routine entries and provide improved compliance and greater control for importers. Direct-filing is also a way for an importer to manage the less complicated import transactions but use the professional knowledge and experience of a licensed CHB when appropriate.
How do we get started with TRG Direct®?
Call us to schedule an on-line demo of the system.
TRG Direct® will assist you in submitting the required documentation to CBP to gain approval for direct-filing.
TRG Direct® will conduct complete training on the ABI system.
How does TRG Direct® assist the importer who wishes to direct-file?
Evaluate whether direct-filing is appropriate for your needs.
We assist you through the entire set-up and training process:
Assist with submission of the required documentation to CBP.
Provide training on the ABI system.
Assist with answering CBP’s ABI test questions.
Do I need to give TBI Brokers (TBIB) a Power of Attorney (POA)?
Yes, you will need to grant TBI Brokers (TBIB) a customs POA.
How are duties paid for entries I’ve filed myself?
Direct-filers pay all CBP duties, taxes and fees, via ACH (Automated Clearing House) or PMS (Periodic Monthly Statement).
Am I required to establish an importer direct-audit process?
No, although we highly recommend that each entry filed with CBP, whether “direct-filed” or filed by your customs broker are reviewed for accuracy. This is consistent with performing your importer responsibilities to undertake reasonable care in the preparation, filing and processing of all CBP documents.
What if I decide that I no longer want to clear my own shipments?
At any time, commercial documents can be turned over to a licensed customs broker for clearance purposes. CBP does not require an importer to direct-file any or all entries even after a filer code has been assigned. TRG Direct® does not require that a direct-filer process all their entries using the TRG Direct® system nor that a direct-filer use the system for a minimum length of time. There are no penalties or costs to stop direct-filing however the $2,500 set-up fee is no-refundable.
Are there any entries that I can’t clear using direct-filing?
It is CBP’s objective to include all entries in the future. However, at present, those with an entry type other than 01 (formal - value over $2000) or 11 (informal – value under $2000) may not be direct-filed. That means any entry involving quota, anti-dumping (ADD), countervailing duty (CVD) or warehouse entries & withdrawls are excluded. In addition, border entries at Mexico and Canada should not be direct-filed.
Am I able to direct-file Canada & Mexico border entries?
Technically, you can file formal (01) and informal (11) entries at either border. However, we do discourage it because of the speed and timing of the transactions as well as the relatively low price already charged by border brokers. Please note that Canada is easier because Canadian trucks are allowed into the US, but shipments from MX must have a MX broker on the other side and it typically involves a lot of coordination with the MX broker and the transferring of the shipment to a US truck.
How do I clear entries requiring release by the Food & Drug Administration (FDA)?
FDA data can be entered into the ABI system as for CBP data. FDA data transmits to CBP first, then is passed to the FDA system. Entries with items requiring FDA clearance cannot be transmitted to CBP without FDA data included.
How do I file the Prior Notice for FDA goods?
If you are filing your entry with CBP prior to the required time limits set by FDA for Prior Notice, then the data required by FDA for clearance is also sent as the data required for Prior Notice. If you are not able to file the CBP entry within the Prior Notice time frame, then an entry can be created that only transmits the Prior Notice data elements required. The entry can be transmitted to CBP and FDA for clearance purposes at a later time.
What if I need help clearing my shipment?
TRG Direct® is a service of TBI Brokers (TBIB), a licensed customs broker. TBIB can either answer questions and assist you with the completion of your direct-filed entry, or clear the entry as would any licensed CHB, on your behalf.
Once cleared, how do I arrange delivery of my shipment?
If the carrier or warehouse uses CBP’s Automated Manifest System (AMS), as most do, they will be able to see the clearance and release information electronically. In this case, only a delivery order will need to be prepared and delivered to the trucker. If the carrier or warehouse is not AMS, a fax of the clearance and a delivery order would be necessary.
How do I handle CBP or PGA exams of my shipments?
You will be notified by either an ABI electronic message, or by phone or fax, depending on the type of exam and the agency involved. Additional steps to be taken are outlined in our manual.
What are the recordkeeping requirements for entries that are direct-filed?
It is the same as for all CBP records: 5 years from the date of entry. You must retain them and be able to produce them in a reasonable time frame upon demand by CBP. This is a requirement of all importers, regardless of whether or not they direct-file.
Are there any additional compliance requirements when direct-filing?
You must always be aware of Partnering Government Agency (PGA) requirements such as FDA. At the time you classify your product for CBP purposes you should determine if any PGA requirement apply, and if so, which agency.
What technology does TRG Direct® use to file the entries with Customs?
TRG Direct® clients log in to TRG Direct® and access CBP's Automated Broker Interface software from their existing computers via the Internet. A secured link to CBP's Automated Broker Interface (ABI) is provided by TRG Direct®. Verisign® technology and SSL (Secure Sockets Layer) security are implemented to ensure secure transport of information. VPN (Virtual Private Network) technology ensures secured transport of information from TRG Direct® to CBP. Importers can direct-file, without investing in new hardware or software, from anywhere there is a computer and an Internet connection.
How is the importer's data stored and backed-up?
Fault tolerant storage systems and clustered server arrangements are used to store and back-up the data. This configuration assures a high level of data availability. A secured data center and frequent tape back-up processes further enhance availability and recovery capability. Database replication processes and encrypted off-site data storage add an extra level of security, availability, and recovery capability.
Once I file an entry, how do I understand the feedback and results I get back from the CBP via the ABI system?
Importers will be given a list of all possible ABI results by TRG Direct® including the meaning of the electronic result, as well as “Next Action Steps” for the importer, depending upon the result.
Can I access my importer data at any time?
TRG Direct® stores a copy of the 7501 information for your use and review. Upon log in, you can print the information for your records. While the electronic information is available for your use, Customs requires that each importer maintain a local copy of their entry information. Requests for historical records of imports from TRG Direct® can be accomodated with adequate advance notice.
Is there a place on the system to store my “Parts” information, and can it be updated electronically?
TRG Direct® has a parts table which is used to add, update and maintain detailed information about the part, such as the country of origin, manufacturer, tariff number and description. The table allows part data to be easily pulled into each entry. The importer’s part information can be uploaded from an excel document by the importer at any time.
How do I arrange payment for services of 3rd party vendors such as, CBP exam sites?
You may choose to set up an account with certain exam sites or other 3rd party vendors, or to submit payment via an overnight courier, whichever is more efficient for your needs.
I have several different product codes/SKUs which are the same tariff number on one commercial invoice. Do I have to enter each invoice line separately, or can I combine them together?
Each SKU will need to be entered separately, since it is possible that an Electronic Invoice Processing (EIP) will be requested by CBP. However, your part / SKU information is retained in the system for easy retrieval and data entry.
Why am I getting a “Duplicate” file message?
Someone has already used this bill of lading number to transmit an ISF --- maybe not your shipment. That is why you are getting the “duplicate” file message --- CBP will accept the ISF for the first importer that uses the bill number and will reject any subsequent filings with the same bill number. So, in order to be compliant with the requirements of ISF and if the carrier cannot discover the error on their part, you could request that they issue you a new bill number so that you can correct your ISF filing and retransmit with another bill number. When you receive a reject for your ISF --- it is as if you have not filed the information with CBP.
Unfortunately CBP has not provided the filers with any advice on what to do to try and solve this problem (and for right now, until Jan. 26 --- there will be no penalty for failing to file an ISF). The only advice we can give is for you to work with the Bill issuer to resolve whatever problem is resulting in your filing being rejected by CBP, with the last resort, your insisting that you need a new bill number so that you can file your ISF.
All of your attempts to resolve this duplicate file reject should be maintained in the system “notes” file to assist with any response to an enforcement action that CBP might take for ISF’s filed after January 26th.
Do rollover shipments need new ISFs?
If you have some cargo that made the shipment but others that are rolled over, you should update the ISF with the information about the cargo that made the shipment. If the ISF has already been transmitted with a bill of lading (BOL) that is being rolled over, you will need to take that BOL off of that ISF as well and request that a new BOL be issued for the rolled over cargo. You will then create a new ISF for the rolled over cargo with the new bill of lading.
If an entire shipment is rolled over, you will need to update the ISF if any of the information has changed, including the new bill of lading. If the information is exactly the same, then you don’t need to do anything.
It may seem difficult to receive a new BOL for a rolled over shipment, but if you have already transmitted an ISF with that BOL, then you will receive a rejected ISF with a Duplicate ISF Transaction error message because Customs will not accept more than one ISF with the same BOL. This can seem problematic, but this is a situation that every vendor will eventually have to deal with and accommodate.
What is an AMS Bill of Lading?
ISF has brought the term “AMS bill of lading” into the importer’s vocabulary, causing even more confusion as to what BOL Customs wants when the importer submits an ISF. The AMS bill of lading is whatever bill of lading is entered into AMS. This is the BOL that you want on your ISF because it is what Customs matches the ISF BOL with the BOL entered into AMS. Even if you believe you import under a house bill or straight bill of lading, it is helpful for you to ask your carrier or freight forwarder for the AMS bill of lading so that you know that your ISF will be matched properly.
Why haven’t I received a response from Customs after filing an ISF?
If you have filed an ISF and have not received a timely response from Customs, don’t worry. This occurs when the CBP’s system gets overloaded and overwhelmed. If this happens, don’t fret; your ISFs have been transmitted and Customs will be aware of the hold up. All you can do is sit and wait for the system to clear up.
Can I file my ISF early?
TRG Direct® recommends filing as soon as you get all of the accurate data elements. However, if you file your Importer Security Filing before the bill of lading is entered into AMS, you will get a No Bill on File message since there is no bill of lading to match it to in AMS. When this happens, the system will cycle the entry through until the bill matches. Filing an ISF as soon as you have the information is a good way to ensure you file timely. The No Bill on File message will not result in a negative result on your progress report. The sooner CBP receives the information the better because this gives them more time to look through the information and screen it.
What is an invalid transaction error?
This occurs if somebody attempts to submit an ISF that has already been submitted by a different entity or the information was the same as a deleted ISF. This happens often if you go back and attempt to resubmit an old ISF or if you change your filer code and attempt to resubmit an ISF.
Definitions of the Entities (Data Elements).
Importer – The entity that is liable for duties and taxes and that is liable for federal regulations when importing into the United States.
Consignee – The entity on whose account the items are shipped. This is usually the same as the Importer.
Ship To – The name and address that will receive the goods as soon as they clear Customs. This is often the Importer.
Manufacturer – The name and address of the company producing the goods.
Seller – The name and address of the person selling the goods. If they are household goods, this is generally the name and address of the owner. This is often the same as the Manufacturer.
Buyer – The name and address of the entity purchasing the goods. If they are household goods, this is generally the name and address of the owner. This is often the Importer and/or Ship To.
Container Stuffing Location – The name and location of the place where the goods will be stuffed into the container.
Consolidator – The person who arranges for the stuffing of the goods.
HTS – Customs accepts both the 6 and 10 digit Harmonized Tariff Schedule number. It is unnecessary to indicate how many of each item.
Country of Origin – Customs requires the country of where each HTS originated.
Bill of Lading – This is known the hidden 11th element. The lowest bill of lading is required for all ISFs.
What are the different ISF transaction types?
A “Compliant Transaction” is used when you are sending 10 accurate ISF data elements. This means you are telling Customs that everything within the ISF is correct (to the best of your knowledge).
“Flexible Range” is used when you are not sure what items will be included in the shipment. If this is the case, you would enter every possible HTS code and file using “Flexible Range.” However, once you receive accurate information, you need to update the ISF before the ship arrives in port. Once you update and retransmit, Customs will consider the ISF a “Compliant Transaction.”
“Flexible Timing” is used when you are unaware of the Consolidator or Stuffing Location. Since these items were not necessary previously, Customs allows you to file your Importer Security Filing under this transaction type without those entities. However, like “Flexible Range,” the ISF must be updated and retransmitted before the ship enters port.
How can I possibly get the Bill of Lading Number on time?
CBP has tried hard to let the shipping community know that the bill of lading has to be issued earlier. Some vendors are using the booking number as the bill of lading to rectify this situation. Most importers require the bill of lading at least 48 hours prior to lading. If you don’t receive the BOL before the ship is laden, you will be late. If you are a TRG Direct® ISF customer, we have letters that you can send to vendors letting them know that you need the essential data elements early. If they don’t comply, we can go to CBP and have them deal with noncompliant vendors.
I have done everything I could to transmit a compliant ISF, but was still unable to do so. How do I let Customs know I tried?
The notes field is a way for customers to make any notes of any peculiarities on a particular ISF. If anything worth noting happens while filing an ISF, it is important that you make a note of it in this field. The notes will not be submitted to Customs, but it is a safety net for you in case you incur any ISF penalties. That way, if CBP attempts to penalize you on an ISF, you can go into your notes field, remind yourself on the circumstances of that particular ISF, and then use it to show Customs that you performed due diligence to file timely and accurately. This can help greatly when trying to mitigate penalties. The notes field can be edited and updated as often as you like.
What is importer direct-filing of customs entries or direct-filing?
Direct-filing is the term used when importers file their own entries directly with Customs and Border Protection (CBP), without the use and expense of a customs broker.
What is Remote Location Filing (RLF)?
RLF allows a filer to file entries at any U.S. port, not only the port the importer is located in.
What is a Filer Code?
CBP assigns a Filer Code to direct-filing importers that conduct business with CBP. Each unique filer code has 3 alpha, numeric or alpha-numeric characters. The importer uses this assigned code as the first three characters of the entry number for all CBP entries.
What does Automated Broker Interface (ABI) mean?
The Automated Broker Interface (ABI) is an element of Custom’s Automated Commercial System (ACS). ABI permits qualified participants to electronically file required import data with CBP. Entry data is transmitted from the importer to CBP and back to the importer via ABI.
What is Automated Clearing House (ACH)?
ACH is an electronic payment option that allows participants to receive refunds, pay CBP fees, duties, and taxes electronically and a requirement for direct-filing.
What is ACE?
CBP's secure data portal designed to enhance national border security and facilitate lawful trade.
What is Periodic Monthly Statement (PMS)?
Periodic Monthly Statement (PMS) is a Custom's program for duty payment. Instead of a transaction-by-transaction payment process, PMS offers an interest-free periodic monthly statement process. Importers or brokers pay for all shipments released during the previous calendar month by the 15th working day of the following month. This benefit is offered to ACE participants.
What is “Electronic Invoice Processing” (EIP)?
Electronic Invoice Processing (EIP) is the ability to transmit your commercial invoice data electronically to CBP via ABI. It is a requirement(s) for direct-filing.