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International Trade

Key Issues for the Toy Industry

10+2 Importer Security Filing 
The Importer Security Filing (ISF) commonly referred to by the trade as “10+2” is a U.S. Customs and Border Protection (CBP) regulation that requires importers and vessel common carriers to provide trade data to CBP in advance of the shipments arriving into the U.S. by vessel (ocean cargo). 

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Automated Commercial Environment (ACE)
The Automated Commercial Environment (ACE) is the commercial trade processing system used by the U.S. to automate border processing, enhance border security and foster our Nation’s economic security through lawful international trade and travel.

When fully developed and implemented ACE will:

  • Allow participants access to and management of their trade information via reports;
  • Expedite legitimate trade by providing CBP with tools to efficiently process imports / exports and move goods quickly across the border;
  • Facilitate efficient collection, collaboration and compliance efforts between CBP and the trade community;
  • Provide an information-sharing platform for trade data between government agencies.
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Certified Cargo Screening Program (CCSP)
The Implementing Recommendations of the 9/11 Commission Act of 2007 required 50% screening of air cargo, at the piece level, by February 2009 and 100% by August 2010. The Transportation Security Administration (TSA) created this voluntary program which is a partnership between industry and government. Domestic facilities that seek approval as CCS facilities are subject to rigorous security regulations by the TSA. 

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C-TPAT (Customs and Trade Partnership against Terrorism)
C-TPAT is a voluntary initiative between government and industry with the goal of strengthening and improving the overall international supply chain and bolster U.S. border security.  C-TPAT participants must ensure the integrity of their security practices and communicate and verify the security guidelines of their business partners within the supply chain.  In return, the companies benefit from “fast lane” border crossings and other important incentives. Companies of all sizes can benefit from C-TPAT membership. 

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Intellectual Property Rights
In recent years, counterfeiting, piracy and other intellectual property rights (IPR) violations have grown in magnitude and complexity, costing businesses billions of dollars in lost revenue and often posing health and safety risks to consumers.  Companies may take steps to protect their IPR by recording, and renewing, trademarks, copyrights and trade names with CBP.

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Lacey Act Amendment
The Lacey Act is the world’s first ban on trade in illegal wood. In 2008 Congress passed a farm bill, which included an amendment to the 100 year old Lacey Act to address illegal logging. The Act:

  1. Prohibits all trade in plant and plant products that are illegally sourced from any U.S. state or foreign country.
  2. Requires importers to declare the country of origin of harvest and species name of all plants contained in their products.
  3. Establishes penalties for violation of the Act, including forfeiture of goods and vessels, fines and jail time.
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Manifest Confidentiality
Simply put, there is a regulation (19CFR 103.31) which requires Importers to file certain trade information with CBP; many of these same data elements are also now required as part of the ISF “10+2” requirements.  It has come to TIA’s attention that certain publications and Internet based operations are selling this trade information.  Section 19 CFR 103.31 allows an Importer to keep its manifest information confidential; confidentiality must be formally requested in writing and renewed every two years. 

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