While the name of the initiative is 10+2, one crucial data element is not considered in the list of the 10 elements required from importers: the bill of lading (BOL). “We call the bill of lading, ‘the mystery 11th element,’ ” says Melissa Irmen, vice president of products and strategy for Charlotte, NC-based Integration Point, Inc. “If you look at the CBP list of the 10 data elements, the bill of lading is not on there, but it is a required data element, and it’s the one giving folks the most heartburn trying to collect in a timely manner.”
The difficulty in acquiring the BOL data may be compounded by the fact that it is not one of the 10 required elements highlighted in the name of the initiative; as such, focus on the BOL may not occur until it is flagged as missing.
Importer Security Filing (ISF) filers are required, 24 hours prior to lading, to report, along with other elements, the lowest-level BOL associated with a shipment. This requirement is problematic when goods are trans-shipped. “This is especially true if a manufacturer is co-loading and going through a non-vessel operating common carrier (NVOCC),” Irmen says.
An NVOCC is a person or company — often a forwarding agent — who does not own or operate the carrying ship, but who contracts with a shipping line to transport a third party’s goods. The NVOCC creates house bills under a master bill with a shipper. Getting that BOL on the vessel has been a challenge. That’s because, while the ISF is input prior to the goods’ being laden in the originating country, the BOL may not be reported to the CBP until the carrier inputs it in the Automated Manifest System (AMS) at the port of trans-shipment.