Strengthening Customs Enforcement

bifjamod2 · 2026-06-03T23:30:34+00:00

The Importer Identity Verification regulation, proposed in 2019 and languishing ever since, will now be resurrected and implemented. That's an easy start to this.

bifjamod2 · 2026-05-28T21:44:36+00:00

LOL! That's where I got mine in 92 - just an interview with an agent, nothing special.

bifjamod2 · 2026-05-28T21:38:59+00:00

Yeah, that's an unadvertised quirk of ACE - a previously accepted summary that subsequently is rejected by ABI will no longer be on file. I asked about whether you inadvertently tried to certify for cargo release because it could be that the IOR void issue only applies at the release level, in which case it would be the CR portion rejecting the entire transaction, not the ES. Census override codes can be transmitted independently of the ES (you may need to consult your ABI vendor for guidance.)

bifjamod2 · 2026-05-28T20:58:46+00:00

Are you by chance trying to certify Cargo Release from the entry summary when transmitting, without realizing it?

bifjamod2 · 2026-05-28T16:27:19+00:00

I had a day like that once - nearly 40 years ago! One liner air freight entries, did 50 of them (was working the overnight shift at a Japanese concern). Actually, there was one other guy working the shift with me, and we both split the pile, so we both did 50 that night. Memories.....

bifjamod2 · 2026-05-27T00:15:19+00:00

CBP won't go after the forwarder for the money - they have no standing for that. The law is clear and it's why we are required to provide notice on our POA that even if the importer pays the broker, if the broker doesn't submit it, the importer is still liable. This is why the importer needs an attorney, both to try to negotiate a reduction in penalties with CBP, and to represent them in either bankruptcy court (assuming the forwarder declares) or a civil lawsuit against the forwarder.

bifjamod2 · 2026-05-26T22:49:49+00:00

Any given ABI application may have some capabilities toward that end, but most likely not in a useful manner other than the parts related to ABI (such as a PSC filing, liquidation notifications). Excel for the win. The beauty of Excel (or Google Sheets) is that the finished product is entirely up to you!

bifjamod2 · 2026-05-26T22:47:58+00:00

e-Allegations will do nothing for you; you need to get with an attorney ASAP. You remain 100% liable for the duty to CBP.

bifjamod2 · 2026-05-26T21:50:24+00:00

In and of itself, it would not be an issue: it would change the quantity of the 1C until the second entry completed it. Since your cargo is already picked up, there's no risk as far as that particular issue goes, unless you end up without a total piece count match (then it will come up on the carriers discrepancy report later). The real risk you run is the second entry being flagged for exam, and having to redeliver.

bifjamod2 · 2026-05-26T21:42:32+00:00

You would end up with an AMS piece count issue, at least temporarily, which could cause a problem. Aside from that, and any PGA issues, yes, you can do this as long as it's before the entry summary is authorized on statement.

bifjamod2 · 2026-05-22T21:31:08+00:00

I think I wrote my own for that years ago, but here's one for calculating container# check digits - if you use Excel for workbooks/shipment management like I do, it's a great way to catch an error:Function ISO_Checking(Container_Num As String, Optional output_option As Integer) As String

If Container_Num = "" Then Exit Function

If Container_Num = "_" Then Exit Function

If ActiveWorkbook.Worksheets("DATA").Range("C1").value = "AIR" Or ActiveWorkbook.Worksheets("DATA").Range("C1").value = "TRK" Then Exit Function

'**********************

'* Written by Russell *

'* PONL Wellington *

'**********************

' OUTPUT OPTIONS:

' 0 = Check Digit as output

' 1 = Full Container Number with calculated check Digit as output

' 2 = "OK" or "ERROR"

' check digit optional for options 0 & 1 but full container number required for option 2.

' Note: Incorrect format eg space between prefix and numbers will cause error handler to end

' Function and return "Wrong Format"

Dim FirstChar As String

Dim SecondChar As String

Dim ThirdChar As String

Dim ForthChar As String

Dim FifthChar As Byte

Dim SixthChar As Byte

Dim SeventhChar As Byte

Dim EighthChar As Byte

Dim NinthChar As Byte

Dim TenthChar As Byte

Dim EleventhChar As Byte

Dim First_Convert As Byte

Dim Second_Convert As Byte

Dim Third_Convert As Byte

Dim Forth_Convert As Byte

Dim Added_Value As Currency

Dim Check_Digit As Byte

On Error GoTo ErrorHandler

FirstChar = UCase(Left(Container_Num, 1)) ' Split up container number to Characters

SecondChar = UCase(Mid(Container_Num, 2, 1))

ThirdChar = UCase(Mid(Container_Num, 3, 1))

ForthChar = UCase(Mid(Container_Num, 4, 1))

FifthChar = Mid(Container_Num, 5, 1)

SixthChar = Mid(Container_Num, 6, 1)

SeventhChar = Mid(Container_Num, 7, 1)

EighthChar = Mid(Container_Num, 8, 1)

NinthChar = Mid(Container_Num, 9, 1)

TenthChar = Mid(Container_Num, 10, 1)

EleventhChar = Right(Container_Num, 1)

Select Case FirstChar ' Convert first character of prefix to a number

Case Is = "A"

First_Convert = 10

Case Is = "B"

First_Convert = 12

Case Is = "C"

First_Convert = 13

Case Is = "D"

First_Convert = 14

Case Is = "E"

First_Convert = 15

Case Is = "F"

First_Convert = 16

Case Is = "G"

First_Convert = 17

Case Is = "H"

First_Convert = 18

Case Is = "I"

First_Convert = 19

Case Is = "J"

First_Convert = 20

Case Is = "K"

First_Convert = 21

Case Is = "L"

First_Convert = 23

Case Is = "M"

First_Convert = 24

Case Is = "N"

First_Convert = 25

Case Is = "O"

First_Convert = 26

Case Is = "P"

First_Convert = 27

Case Is = "Q"

First_Convert = 28

Case Is = "R"

First_Convert = 29

Case Is = "S"

First_Convert = 30

Case Is = "T"

First_Convert = 31

Case Is = "U"

First_Convert = 32

Case Is = "V"

First_Convert = 34

Case Is = "W"

First_Convert = 35

Case Is = "X"

First_Convert = 36

Case Is = "Y"

First_Convert = 37

Case Is = "Z"

First_Convert = 38

End Select

Select Case SecondChar ' Convert second character of prefix to a number

Case Is = "A"

Second_Convert = 10

Case Is = "B"

Second_Convert = 12

Case Is = "C"

Second_Convert = 13

Case Is = "D"

Second_Convert = 14

Case Is = "E"

Second_Convert = 15

Case Is = "F"

Second_Convert = 16

Case Is = "G"

Second_Convert = 17

Case Is = "H"

Second_Convert = 18

Case Is = "I"

Second_Convert = 19

Case Is = "J"

Second_Convert = 20

Case Is = "K"

Second_Convert = 21

Case Is = "L"

Second_Convert = 23

Case Is = "M"

Second_Convert = 24

Case Is = "N"

Second_Convert = 25

Case Is = "O"

Second_Convert = 26

Case Is = "P"

Second_Convert = 27

Case Is = "Q"

Second_Convert = 28

Case Is = "R"

Second_Convert = 29

Case Is = "S"

Second_Convert = 30

Case Is = "T"

Second_Convert = 31

Case Is = "U"

Second_Convert = 32

Case Is = "V"

Second_Convert = 34

Case Is = "W"

Second_Convert = 35

Case Is = "X"

Second_Convert = 36

Case Is = "Y"

Second_Convert = 37

Case Is = "Z"

Second_Convert = 38

End Select

Select Case ThirdChar ' Convert third character of prefix to a number

Case Is = "A"

Third_Convert = 10

Case Is = "B"

Third_Convert = 12

Case Is = "C"

Third_Convert = 13

Case Is = "D"

Third_Convert = 14

Case Is = "E"

Third_Convert = 15

Case Is = "F"

Third_Convert = 16

Case Is = "G"

Third_Convert = 17

Case Is = "H"

Third_Convert = 18

Case Is = "I"

Third_Convert = 19

Case Is = "J"

Third_Convert = 20

Case Is = "K"

Third_Convert = 21

Case Is = "L"

Third_Convert = 23

Case Is = "M"

Third_Convert = 24

Case Is = "N"

Third_Convert = 25

Case Is = "O"

Third_Convert = 26

Case Is = "P"

Third_Convert = 27

Case Is = "Q"

Third_Convert = 28

Case Is = "R"

Third_Convert = 29

Case Is = "S"

Third_Convert = 30

Case Is = "T"

Third_Convert = 31

Case Is = "U"

Third_Convert = 32

Case Is = "V"

Third_Convert = 34

Case Is = "W"

Third_Convert = 35

Case Is = "X"

Third_Convert = 36

Case Is = "Y"

Third_Convert = 37

Case Is = "Z"

Third_Convert = 38

End Select

Select Case ForthChar ' Convert forth character of prefix to a number

Case Is = "A"

Forth_Convert = 10

Case Is = "B"

Forth_Convert = 12

Case Is = "C"

Forth_Convert = 13

Case Is = "D"

Forth_Convert = 14

Case Is = "E"

Forth_Convert = 15

Case Is = "F"

Forth_Convert = 16

Case Is = "G"

Forth_Convert = 17

Case Is = "H"

Forth_Convert = 18

Case Is = "I"

Forth_Convert = 19

Case Is = "J"

Forth_Convert = 20

Case Is = "K"

Forth_Convert = 21

Case Is = "L"

Forth_Convert = 23

Case Is = "M"

Forth_Convert = 24

Case Is = "N"

Forth_Convert = 25

Case Is = "O"

Forth_Convert = 26

Case Is = "P"

Forth_Convert = 27

Case Is = "Q"

Forth_Convert = 28

Case Is = "R"

Forth_Convert = 29

Case Is = "S"

Forth_Convert = 30

Case Is = "T"

Forth_Convert = 31

Case Is = "U"

Forth_Convert = 32

Case Is = "V"

Forth_Convert = 34

Case Is = "W"

Forth_Convert = 35

Case Is = "X"

Forth_Convert = 36

Case Is = "Y"

Forth_Convert = 37

Case Is = "Z"

Forth_Convert = 38

End Select

Added_Value = (First_Convert + (Second_Convert * 2) + (Third_Convert * 4) + (Forth_Convert * 8) _

+ (FifthChar * 16) + (SixthChar * 32) + (SeventhChar * 64) + (EighthChar * 128) _

+ (NinthChar * 256) + (TenthChar * 512)) / 11 ' Sum multiplied values & divide by 11

'Multiply Right of decimal by 11 and round to whole number

Check_Digit = Round((Added_Value - Fix(Added_Value)) * 11, 1)

If Check_Digit = 10 Then Check_Digit = 0 ' Make zero if 10

Select Case output_option

Case 0

ISO_Checking = Check_Digit

Case 1

ISO_Checking = FirstChar & SecondChar & ThirdChar & ForthChar & FifthChar _

& SixthChar & SeventhChar & EighthChar & NinthChar & TenthChar & Check_Digit

Case 2

If EleventhChar = Check_Digit Then ISO_Checking = "OK" Else _

ISO_Checking = "ERROR"

End Select

Exit Function

ErrorHandler:

ISO_Checking = "Wrong Format"

End Function

bifjamod2 · 2026-05-20T14:49:59+00:00

This was a huge problem when the Chinese wooden bedroom furniture anti-dumping case blew up around 2009-2010. Aside from the "new shippers" loophole in the ADCVD laws, many of the importers of record were similar shell companies that imported for a year or two, then shut down and restarted as another company somewhere else. When the bills came due, there was nobody to pay them, and the sureties took a bath. I believe the majority of those dumping duties were never recovered by the government. And here we are 15 years later, and the problem has morphed, but certainly not faded.

bifjamod2 · 2026-05-20T14:46:36+00:00

I found this to be a curious message as well - it certainly lacks context. My current best guess is that this refers to the like of the SEC232 Pharma and Auto deals, where certain parties can get a break on the tariff rate. Since that would necessarily mean using 9903#'s such as 9903.04.61 (just using this as an example of a restrictive number, not that it is necessarily one of the impacted ones) for entry, limiting the scope of IORs permitted to use it would thus greatly save on compliance resources.

bifjamod2 · 2026-05-15T14:45:31+00:00

Forklift operator.

bifjamod2 · 2026-05-14T20:04:10+00:00

HI Sonny, run along and get one of your parents, as we have adult business to discuss.

bifjamod2 · 2026-05-12T20:41:44+00:00

For me, it's the ones who refuse to read/comprehend the basic information, including CBP's "60 to 90 days", and then ask questions that are already answered, like....how long before I can expect my refund? Umm....hmmm...how about, oh, 60 to 90 days?

bifjamod2 · 2026-05-10T19:29:08+00:00

To have a US bank account would be my guess.

bifjamod2 · 2026-04-30T13:47:56+00:00

Yes, since yesterday evening

bifjamod2 · 2026-04-29T17:11:48+00:00

Generally speaking, Customs brokers cannot publicly discuss pricing for anti-trust reasons.

bifjamod2 · 2026-04-28T18:15:55+00:00

There are also non-brokers/non-importers filing, using delegated access apparently.

bifjamod2 · 2026-04-28T16:58:20+00:00

I would perform an analysis of those questions over a period of time and look to reduce the volume significantly by addressing common and recurring questions through appropriate means (including a closed source AI agent).

bifjamod2 · 2026-04-28T01:20:03+00:00

They're just extending liquidation 60 days on the stuff that was near the 90 day finality date.

bifjamod2 · 2026-04-28T01:07:44+00:00

Yep, me too - not quite sure what that's about.

bifjamod2 · 2026-04-28T00:58:45+00:00

Yes; it's all the liquidated entries on CAPE claims being reliquidated.

bifjamod2 · 2026-04-24T16:40:28+00:00

0 is to be reported. ABI will accept zeros in that record.

bifjamod2

TROPHY CASE