Nearly all shipments over the ocean require an Importer Security Filing (ISF or ISF+10) before those goods are admitted and processed on US soil. These ISFs are part of the security and threat targeting systems used by CBP and the Department of Homeland Security (DHS) to identify and target risky or significant shipments as early as possible.

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ISFs are to be filed at least 72 hours before the vessel departs the foreign port, and missing ISFs will result in a CBP hold on the entire container or containers related to your shipment. Although Pilotfisch will review for ISF status as an early setup process, we encourage importers to verify their ISF filer or designate that Pilotfisch ought to handle that responsibility. In the event that your shipment is missing an ISF and already underway, Pilotfisch will help file your ISF as soon as possible to minimize risk exposure. While CBP penalties and liquidated damages are usually assessed for repeat offenders, CBP's atmosphere of increased enforcement (for the purpose of higher revenues) means that sloppy ISF behavior leaves your entity increasingly exposed.

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Please note that ISFs are a formal filing with US Customs and are therefore subject to customs bonding requirements. Continuous customs (entry) bonding will include ISF activities, but single transaction (entry) bonding does not. If using single transaction bonding methodology, the ISF filing will require a separate ISF bond in tandem.

Certificates of Origin (or sometimes called Certificates of Manufacture) are used as evidence for trade agreements, tariff programs, as well as Customs audits as evidence for proper treatment of those goods. As supply chains and manufacturing processes become increasingly complex, bad actors are using that complexity to mask the true nature and source of goods. These certificates are used to identify the source location and material facts of those goods so that CBP and other Partnering Governmental Agencies (PGAs) can more easily identify and isolate fraud and nefarious activity.

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Pilotfisch Solutions encourages importers to build a habit so that these certificates are affiliated with as many products as possible. Our first priority will be to review your shipment for any required certificates of origin or manufacture, but we can also be a resource to help you improve and align these certificates so that they are increasingly robust with significant information. Not only can these certificates protect your shipment from improper treatment, you can use these documents as evidence of your entity's diligence despite fraud or bad-faith activities outside your knowledge or control.   

Certain products require import licenses or certificates of conditional approval from the governing Partnering Governmental Agency (PGA) before your product is allowed entry into the US commerce. These PGAs often issue and regulate the licenses or approvals directly, with their own restrictions and methods for securing approval. Some examples include FDA medical device registration and facility registrations, TTB certificates of label approval (COLA), BIS steel import licenses, or FWS CITES permits.

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Pilotfisch suggests that importers work with their origin agents and PGAs directly to review and satisfy each license, registration, or approval. Pilotfisch is able to review and guide importers through the specific importation processes related to their shipment, but it is far better to be confident and prepared before the shipment initiates (rather than upon arrival into the US.)

Similar to Import Licenses, PGAs require importers to be knowledgeable about the goods they are importing, so the correct declarations can be made at time of importation. These declarations are often in the form of a PGA import form, online data uploads, or sometimes as simple as a written affidavit from the importer. Be confident in the details of your goods so that you avoid issues and mistakes on these declarations. 

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Pilotfisch will work with you and your technical teams to confirm understanding from both regulatory and operational perspectives. While we can identify what forms or statements may be needed, we will rely on you and your expert knowledge of the products to select whatever appropriate description or claim. CBP has become the enforcer for all PGA controls on imports, but neither CBP nor Pilotfisch are specialists in each PGA -- there are PGA inspectors and specialists now! We will do our best to assist you in PGA compliance, but at certain thresholds we will refer you for specialist help.

Certain products have industry testing or PGA-related review expectations, which may or may not be explicitly required as part of CBP's reporting requirements. Despite CBP's enforcement of PGA concerns, we've found that robust supporting documentation can satisfy certain regulatory concerns in the early inter-agency actions. Certificates of Conformity, certified laboratory results, and other product specific accreditation should be gathered as part of the supporting documentation each time you introduce new import products.

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Pilotfisch will only treat the certain known product concerns as requirements, but you need to have this information prepared for the moment PGA inspectors ask. We prefer to create compliance briefs and strategies so that examinations or issues are deftly mitigated - but you can keep it close to the chest until the time comes when we need to know.

If your shipment needs special handling, loading or unloading considerations; that information needs to be available for any stevedores or physical handlers. Certain goods must be loaded with special equipment, lifted by certain reinforced points, climate controlled, or even specifically organized. Just as a refrigerated shipment may spoil if exposed to heat, machines may be irreparably harmed by unfamiliar or undirected handling.

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Not only do we suggest that you include any special handling instructions with your other shipment documentation (affixed to your goods), we also ask that you help confirm Pilotfisch's understanding of your instructions and how they affect your product(s). We want to be confident and competent if ever terminal or port handling agents contact us in moments of difficulty.