TRADE ALERT

U.S. CUSTOMS & BORDER PROTECTION (CBP) ISSUES ADVICE ON

“VOIDED IMPORTER RECORDS”

(September 21, 2006)

The Importer Identification Numbers File (SRE) in U.S. Customs & Border Protection (CBP), Automated Commercial System is the single most important file. All import transactions and all ACS processing interact with the SRE file. This file contains unique identifying numbers and corresponding names and addresses for all parties involved in import transactions. The SRE file has evolved into a critical component of Customs Fiscal, Legal, and Enforcement Programs. The Numbers (EIN (U.S. Employer’s Identification Number, U.S. Customs & Border Protection (CBP) Assigned Number, and U.S. Social Security Number), Name, and Address conveyed and registered with Customs via a CF 5106 are the basis for establishing Bond Coverage, Release and Entry of Merchandise, Liquidation, Issuance of Bills and Refunds, and Processing of Drawback and Fines, Penalties & Forfeiture (FP&F) Actions.

It is the responsibility of the Importing Party, whatever their role in the Transaction, “Importer of Record”, “Sold To”, or “Ship To”, to provide verified and accurate data to their Entry Filer/U.S. Customs Broker. Accurate Data eliminates the possibility of the voiding of Importing Party Records by CBP, and the subsequent time consuming process of reinstatement.

Should CBP “Importing Party” Data be voided, it could cause a suspension of importing privileges for up to 2 days or more, while processing a reinstatement runs its course. Any data provided by an Importing Party that is knowingly invalid will result in Penalty under 19 USC 1592, the Fraud Statute.

The only documentation that is acceptable proof of the Importer of Record Number would be a copy of the Social Security Card (front & back) if the Importer of Record Number used a Social Security Number. For importer records based on Employer Identification Numbers (EINs), acceptable proof includes documentation received by the Importer from the U.S. Internal Revenue Service (IRS) on IRS letterhead, or an official IRS form showing the Company Name and EIN. Documentation from the IRS must not be more than 1 year old.

Deringer recommends that our valued customers partner with us to ensure that all data that appears on documentation is complete and correct. No one wants costly delays at the border or penalty assessments, which may occur if CBP detects that the data we transmitted on your behalf is incomplete or incorrect. Because goods move twenty-four hours a day, seven days a week, it is often impossible to validate the information we receive on your documents when the goods arrive. Please help us by ensuring that you obtain the correct EIN or SS number from your U.S. buyer before you ship, and that it appears accurately formatted on your documentation.

For more information regarding this advisory, please contact your local Deringer office at 800-448-8108.