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Two years in, a basic ISF guide
On January 26, 2009, CBP began accepting ISF transmissions for freight that would arrive on an ocean vessel at a US ocean port. It has never been a question of whether CBP would begin penalizing those who do not comply; instead, it was always a question of when and to what degree.
On January 26, 2010 CBP began official enforcement of the ISF regulations. Now, a year later, full enforcement has become more of a reality. CBP is placing holds on shipments that have arrived in the US without an ISF filing, in addition to advising that liquidated damages fines will assessed in the very near future.
Import Security Filing (ISF) must be transmitted to US Customs and Border Protection (CBP) for all shipments that will arrive at a US ocean port via an ocean vessel, and there are no exceptions in the ISF regulations for containerized freight. The ISF importer is ultimately responsible for the timely, accurate, and complete submission of the Importer Security Filing.
There is "flexible range" of information for four data elements: manufacturer, and/or ship to party, and/or country of origin, and/or commodity HTSUS. Since exact information for these four elements may not be known prior to departure of the freight, ISF can initially be transmitted with the best available information. However, the ISF must be updated as soon as more precise or more accurate information is available, but in no event less than 24 hours prior to arrival at a US port.
There is "flexible timing" regarding two data elements: the container stuffing location and/or the consolidator (stuffer) ISF.
Prior to the shipment being laden onto the vessel bringing it to the US, an ISF can be timely filed without these two data elements being transmitted. These elements must also be filed as soon as possible, but no later than 24 hours prior to arrival at a US port.
An ISF is not considered complete until all "flexible" data elements are finalized. If freight has arrived at a US port without a complete and accurate ISF, then the filing is considered late and release of the freight will be delayed until both the ISF is accepted complete and the CBP cargo release has been processed.
While it is easy to be mislead by the previous lack of fines and penalties from CBP for ISF noncompliance, CBP promises that future failures to comply will result in a much more punitive response.
Customs is expected to issue the finalized regulations as soon as this March.
Here is a link to CBP's ISF page, which includes the latest FAQ:
http://www.cbp.gov/xp/cgov/trade/cargo_security/carriers/security_filing/
Opting out of chassis rental fees on FCL containers
A new industry trend has been emerging among the steamship line community. Most carriers are now opting out of chassis handling and the responsibility has been passed along to the trucker. This additional expense will be passed on to the shipper or importer.
As an example, effective February 1, chassis fee is $25 per day for moves with Maersk and CMA/CGM. Fee may vary by region and/or by carrier involved.
International shipping lines assess congestion surcharge to Manila Cargo
According to the Philippines News Agency, several international shipping lines servicing Manila's South Harbor and the Manila International Container Terminal (MICT) have started imposing a congestion surcharge the equivalent of US $50 for each TEU and US $100 for each FEU for all inbound and outbound containers. Foreign shipping companies made this decision due to the chronic traffic jams in the said ports, which is preventing them from disembarking and loading cargoes immediately. This fee arrives as an addition to the container imbalance charge (CIC) being collected by carriers for shipping empty containers out of Manila.
Meanwhile, congestion at the South Harbor and MICT has somewhat eased with operators of the two facilities sending some of their empty containers to their respective Batangas and Subic terminals. Several shipping lines have also begun picking up their empties at South Harbor and the MICT. This process, however, still requires five to eight hours for a truck to drop an empty container at any of the ports and a similar length of time to carry a laden container out of the port facilities. According to the Philippine International Seafreight Forwarders Association (PISFA), the greatest burden will be shouldered by the public with the application of the new surcharge. The group added that the forwarders are also somewhat affected as they will have to pay for the surcharges and may need a payment guarantee from their customers in order to get reimbursed.
Source: Cargonews Express, January 2011
Carrier operations – taking an inside look
There is more than meets the eye to carrier operations. Using one APL vessel as an example, the following shipment scenario provides an overview of how APL line connects its vessel, terminal and intermodal teams together.
The APL Holland's arrival at port in Los Angeles at 5 p.m. on September 29 triggered what appeared to be a flawless response at Eagle Marine Services' terminal, as both humans and machines prepared to work the fully laden containership. The master schedule for this particular ship, along with the entire APL fleet for that matter, is meticulously detailed up to a year in advance. The schedule is routinely analyzed and updated to reflect a highly coordinated effort of the commercial and operational departments of NOL Group, the parent company of APL liner services and Eagle Marine Services.
Long before the vessel is sighted on the horizon, APL can not only ascertain from the schedule what side the ship will be tied up at the berth but also determine the exact location of every container and its priority coming off each vessel. This is a side of the container transport business that many shippers never see. They know only that their cargo is booked with the carrier and expect it delivered to a certain location on a certain date.
APL gives its vessels a 4 hour tolerance for when they are scheduled to arrive in port. This allows for customs and other regulatory processing of the ship's crew and cargo – before any discharge or loading work begins. In the final minutes of the 5,500 TEU APL Holland's approach to the terminal, Eagle Marine's 12 gantry cranes began a coordinated shuffle of sorts along the pier. Four cranes previously working the larger APL Tennessee, moved into place alongside the APL Holland, while the cranes that were finishing the APL Korea took up position at the APL Tennessee. The larger APL Tennessee required three days of handling that week, while the APL Holland was scheduled to depart in 24 hours.
Due to unforeseen changes to sailing schedules, vessel-to-terminal connections do not always operate like clockwork. The liner can suffer severe congestion and tightening of space on container ships when there is an unexpected acceleration in cargo volumes. According to Jim Dwyer, VP of global network operations for APL in Singapore, "When one ship in the system is delayed it has an impact on the other ships and terminals in the string. We then have to figure out how to react to the circumstances. It's common to do this particularly when the Asia terminals get behind by congestion and bad weather."
During discharge, the APL Holland's inbound containers waste little time on the docks before demurrage is assessed on the shipper. In June 2006, the Port of Los Angeles reduced its free-time policy from five days to four days (imports) and six days to five days (exports). Although this narrow window adds to the pressure, Eagle Marine executives prefer to minimize container dwell-time on the 292 acre terminal. "Our philosophy is that import containers stay on wheels; empties can be grounded; and exports may be grounded but grouped together for particular ships" say Jack Cutler, Eagle Marine's port manager in Los Angeles.
Containers designated for on-dock rail are out the gate and on a unit train in 24 to 36 hours, while others may be trucked to an offsite railhead within two days. Pick up by truck for local and regional traffic is generally completed within three to four days.
Intermodal connections in the Port of Los Angeles are especially complex since three large container terminals, including Eagle Marine, feed the same rail network. "We must coordinate between the terminals because we all have to share those tracks," Cutler said. "By 10 days out, we all know what the volumes are." They have devised a system whereby the trucker from the intermodal yard can pick up a container and take it to the train within five minutes after discharge. Eagle Marine can move 210 containers from ship to an intermodal unit train from 8 am to 5 pm.
For tactical reasons, Eagle Marine maintains a central meeting space within each of its terminal buildings, often referred to as the "war room." A core group of people from the various terminal departments meets twice daily to decide how best to apply resources to handle the day's cargo flows. The group meets first at 10:30 a.m. to prepare for the evening's workload and again at 4 p.m. for the next morning. The week prior to the APL Holland's arrival as described above, Eagle Marine's terminal handled a record 21,000 container lifts, more than 15,000 gate moves and 7,000 rail lifts.
"It's a lot to concentrate on, and we have to plan so all this traffic doesn't bump into each other," Cutler said.
The war room meetings determine daily workloads, not just in terms of container volumes, but also in the amount of labor and trucks required to handle them.
Source: American Shipper, January 2011
THE PARTING WAVE
It is not the ship so much as the skillful sailing that assures the prosperous voyage.
- George William Curtis
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