The importing and exporting of products and materials was a lot easier pre-9-11 for the buying organization. Post-9-11, the newly formed Department of Homeland Security and its agencies have been diligently at work formulating regulations to prevent dangerous goods from arriving at any of the over 300 U.S. seaports. Many foreign countries are implementing rigorous importing processes, as well.

For those organizations importing goods into the United States today, compliance regulations now rest on the shoulders of the “importer of record.” No longer can an importer or exporter just hand off the process to a third party. There are excellent parcel services just waiting to work with importers and exporters in creating successful global shipments, but now the importer of record must be a participating partner in the process. Many of these third-party providers offer online information, software, tracking mechanisms and document templates for importers and exporters.

Those responsible for the importing and exporting processes within their organizations should make reading Title 15 (exporting) and Title 19 (Customs) of the Code of Federal Regulations ( mandatory. Other helpful web sites are (Customs Border and Protection), (Export Regulations Authority) and (U.S. Census). 

What are some of the facts an “importer of record” should know?

The U.S. Customs and Border Protection requires advance electronic presentation of cargo information for all imports into the United States. Trade Act 2002 mandates the pre-manifesting of all Master Air Waybill (MAWB) and House Air Waybill (HAWB) data via the Automated Manifest System (AMS) at the first US port of entry.

When merchandise is consolidated for shipment, then it is recommended that a detailed consolidation manifest accompany each consolidation. This manifest should include full shipper and consignee information, as well as HAWB pieces, weight and a complete description of the commodity being shipped. 

For CBP compliance, consolidation is any shipment where a House Air Waybill (HAWB) is associated with a Master Air Waybill (MAWB). A simple shipment is one where the shipper and consignee stated on the source document are the ultimate shipper and consignee involved with the shipment.

Any “importer of record” should acquaint themselves with the various documents:
a. Air Waybill of lading
b. Customs Entry Summary (7501)
c. Country of Origin (3229)
d. Commercial Invoice
e. Customs Invoice (3347)
These may be downloaded from, a consolidator or other 
locations on the Internet.

Simple shipments must also have any internal piece counts (also known as Shipper Load and Count, or SLAC) expressed on the source document in the Nature and Quantity of Goods box. For example, if a shipment consists of two skids, each containing 25 pieces, ‘2’ would be entered in the No. of Pieces box, while the Nature and Quantity of Goods box would show ‘SLAC’ – 50 pieces. The number of pieces loaded into Customer Loaded Containers (CLCs) should also be shown in a similar manner, using the term ‘Said to Contain.’ If a CLC containing 150 pieces is tendered, the air waybill would have ‘1’ entered No. of Pieces, with ‘Said to Contain 150’ pieces shown in the Nature and Quantity of Goods box.

The CBP regulations require a precise narrative description of the commodities shipped in order to identify the shapes, physical characteristics and likely packaging of the manifested cargo so that CBP can identify any anomalies in the cargo. Descriptions are available on The customs are attempting to identify anything that would flag a possible problem.

Freight All Kinds (FAK), General Cargo, Said to Contain where it pertains to a description of the goods being shipped (STC), Consol with Consol or Co-Load are no longer acceptable descriptions for consolidated shipments.

For merchandise arriving in the United States by air, the name and nationality of the importing airline are required. The importing airline is the airline carrying the merchandise from the foreign port of lading to the first US port of lading. 

For merchandise arriving in the United States by means of transportation other than vessel or air, the means of transportation from the foreign country is required, in such terms as “parcel post” or “registered mail.”

The name and country of the foreign port at which the merchandise was actually loaded on the vessel or aircraft that carried the merchandise to the US are required.

For merchandise transshipped overseas in the course of shipment to the US, whether or not covered by a through bill of lading, the information furnished shall reflect only the foreign port at which the merchandise was loaded on the vessel, aircraft or other carrier that transported it to the first US port of lading.

County of origin shall be reported in terms designated in Schedule C-1, “Classification of Country and Territory Designations for U.S. Import Statistics.” (Annex A – Schedule C, Classification of Country and Territory Designations for U.S. Import Statistics. D-3 ... Harmonized Tariff Schedule of the United States. Copyright 2009.  

The “country of origin” is defined as the country in which the product was mined, grown, or manufactured. If further labor, work, or materials is added to an article in another foreign country, it must effect a substantial transformation for the later country to be noted “country of origin.” Title 19 of the CFR provides significant details in marking, labeling, and exemptions.

Customs Entry Summary document (7501) must include “country of origin” and duty rate indicated separately against each item (or group of items). 

The Lacey Act (16 U.S.C 3371 et seq., the Act) makes it unlawful to import, export, transport, sell, receive, acquire or purchase in interstate or foreign commerce any plant with some limited exceptions, taken or traded in violation of the laws of the U.S. State or foreign country. A declaration is required to obtain release of such product.

The Transportation Security Administration has implemented the Certified Cargo Screening Program to help the air cargo industry meet new security requirements contained in the 9/11 Commission Act of 2007, which requires 50% of all cargo carried on a passenger aircraft in the US to be screened. Since October of 2009, the TSA has required 100% screening for all cargo on narrow-bodied passenger planes (planes with a single aisle) accounting for 95% of all US flights. In August of 2010, the 100% screening requirements began to apply to all flights. This screening may impact the importer’s products by exposing them to harmful x-rays.

Wood packaging material, such as crates, boxes and dunnage used to support or brace cargo, must be treated and marked. The approved treatment for wood packaging and dunnage includes either heat treatment or fumigation with methyl bromide. Certification of the treatment must be marked with the proper Plant Protection Convention (IPPC) logo.

Due to recent changes in Air Transportation Safety, it is recommended that shippers use “only” clear plastic shrink wrap (not black).

For all palletized freight and individual crates/cases over 140 lbs, band all sides with heavy metal or unbreakable plastic banding and cover on all sides with heavy clear shrink wrap.

Transportation poses many possible supply chain disruptions as well as liabilities. So, the “importer of record” must pick their third-party provider carefully, work closely with them and be able to speak knowledgeably about the importing and exporting process.

Marilyn Gettinger is owner of New Directions Consulting Group. An organization offering customized workshops and a team-oriented consulting method to assist organizations in being successful in their global supply chains management. Marilyn can be reached at or at 908-709-0656. For more information on importing and exporting, please contact her. To learn more about New Directions Consulting Group, check out