“K” Line:  FAQs focusing on Compliance with U.S. Customs 
24 Hour Advanced Manifest Rule

1. Question: How will I know the “K” Line bill of lading cutoff time for submission at the port of loading?

   Answer:  “K” Line has posted Far East and European documentation cut-off tables to the Internet link below, additionally, the “K” Line booking office will advise at time booking is made and confirmed.

   http://www.kline.com/KAMCompliance/USCBP_Advanced_Cargo_Manifest_Overview.asp

2. Question: I am not sure whether I prepared my bill of lading in accordance with U.S. Customs requirement.

   Answer:  Utilize Customs website: www.customs.gov they have a section on the 24-hour rule and their own FAQs.  Additionally, you can verify points on the “K” Line website link: http://www.kline.com/KAMCompliance/USCBP_Advanced_Cargo_Manifest_BL_Preparation.asp

   Special Note: Every bill of lading party must have a complete address to avoid rejection by Custom's system. A rejection will not start the 24-hour clock which measures time prior to loading.

3. Question: What will Customs require as adequate cargo descriptions?

   Answer: Customs will accept either a HTSUS (6 digit Harmonized Tariff number) or a precise narrative description.  Precise is defined by Customs as enough for Customs to be able to identify shapes, physical characteristics, and likely packaging of the manifested cargo so that Customs can identify any anomalies in the cargo when a container is run through imaging equipment.  The description should also be precise enough to identify any goods, which may emit radiation.  

   Descriptions not acceptable are:

   -FAK
   -Blank description field
   -STC

   Customs has posted a sample of acceptable and not acceptable descriptions on their website FAQs www.customs.gov under question # 30.

4. Question: What if the consignee party is “To Order”, or consignee is located in a foreign country, such as Canada or Mexico? Does data element #9 for Consignee or  “To Order” Bills of Lading require a U.S. name and address?

   Answer:  Consignee fields require a full name and address in the USA. For  “to order bills”, the [first] notify party can be the owner's representative as long as a U.S. name and address is provided.  We repeat that the consignee, even if “To Order” must have a U.S. address.

5. Question: I have been contacted by the “K” Line booking office advising my bill of lading is not compliant according to the Customs 24 Hour Rule and the cut-off has passed for submission to Customs, will my cargo still load the vessel?

   Answer: ”K” Line will not load cargo if the bill of lading is not in accordance with Customs requirements.

6. Question: I am a NVO and have filed my manifest via AMS, but am not receiving proper US Customs' clearance messages.  Why would that be?

   Answer: It's very important that the customers' customs broker prepare the entry against the Master B/L.  Failure to do this correctly may likely cause the cargo to not receive customs clearance, delay availablilty and possibly even incure demurrage if not adjusted timely.

7. Question: There is an error in my bill of lading that was already submitted prior to the 24 hour documentation cut-off, should I make the correction and will I receive a Customs hold or a Customs penalty?

   Answer: It is critical to ensure all criteria is met and all parties to the B/L contain full addresses to avoid problems with Customs. Corrections are necessary and “might” increase the chance of Customs targeting dependent on what is being amended.  We cannot predict whether Customs will assess penalties, it will be dependent on the nature of the issue.  It is better to make corrections than to be caught with inaccurate or fraudulent information. NOTE: Customs will be publishing an update on manifest correction procedures in the near future.

8. Question: I am a non-automated NVOCC with shipments destined to both, port of discharge and inland locations. What bonds do I need to do in order to become a fully functional AMS NVOCC? 

   Answer: To become an AMS NVOCC, you will need to obtain the following types of Customs Bonds:

   1. Type 3: International Carrier Bond: The purpose is to cover vessel carriage and submit their House B/L data via AMS in the same way as Vessel Carriers do.
   2. Type 2: Custodial Bond: This bond covers transportation of not yet Customs cleared cargo from port of discharge to another Customs district (ie: inland destination), and the purpose is for AMS-NVOCC to apply I.T. entry to U.S. Custom for Carriers' inland transportation.  
        

9. Question: As a new AMS NVOCC, I do not understand the Customs Release Process for  inland/intermodal  cargo clearing that requires an I.T. or T.E.

   Answer:

   • U.S. Customs allows cargo that enters the U.S. to move away from the discharge port into the interior of the country prior to the cargo being cleared by U.S. Customs.  This allows the cargo to start its intermodal/inleand movement immediately after discharge without being delayed at the port of discharge during the process of clearing U.S. Customs. 
   • All cargo that is moved away from the discharge port prior to its having cleared U.S. Customs must move under the coverage of a custodial bond and is referred to as “in-bond” cargo.  The custodial bond acts as an insurance policy against which Customs will assess any penalties that may be levied against the bond holder for failure to properly declare and clear in-bond cargo.
   • Customs requires that an in-bond document be filed for all cargo that will move away from the discharge port prior to Customs' clearance.  The document used for most intermodal shipments is an I.T. (Immediate Transportation).  The I.T. allows cargo to move from the discharge port's Customs district to another Customs district within the U.S.  A “T&E” (Transportation and Export) is issued for cargo that discharges in the U.S. and will move overland to a foreign destination (e.g., cross border into Canada or Mexico).
   • The I.T. or T&E document must state the bond under which the cargo is moving.
   • In-bond documents may be submitted to U.S. Customs in a hard-copy paper form or as a paperless document.  Electronic submission requires that the filer be a participant in Customs'  “paperless master in-bond” program.  This program is open to AMS participants.
   • Paperless in-bond participants must have the capability to (a) calculate and submit the I.T. number, submit the IRS number of the custodial bond holder and the U.S. Customs district/port code of the inland Customs clearance location in their AMS transmissions and (b) transmit an “in-bond arrival” message to U.S. Customs when the cargo reaches the inland Customs clearance point.  U.S. Customs will not release Customs' status of the cargo until the in-bond arrival has been reported.
       

10. Question: AMS NVOCCs are required to immediately transmit the vessel arrival data to U.S. Customs, how will “K” Line provide timely information?

    Answer: Any customer may get vessel arrival by using the Global Sailing Schedule system that is accessible on our internet site: www.kline.com