Regarding Customs 24-Hour Notification Measure,

Washington, DC: In a joint comment letter signed by National Customs Brokers and Forwarders Association of America, Inc., (NCBFAA) President Federico Zuniga, several organizations representing transportation logistics industry participants expressed opposition to the U.S. Customs Service's August 8, 2002, proposal requiring 24-hour notification prior to lading cargo on board a vessel at a foreign port. 
        Joining with the NCBFAA in submitting these comments were the Business Alliance for Customs Modernization (BACM); American Association of Exporters and Importers (AAEI); Joint Industry Group (JIG); Pacific Coast Council of Freight Forwarders and Customs Brokers (PCC); The International Association of NVOCCS, Inc.; and Los Angeles Customs Brokers and Freight Forwarders Association. 
        "The unintended affect of these proposals will be to severely impede the normal commercial flow of trade," according to the comments, "and will adversely impact the business of importers, as well as those entities involved in the transportation of imported goods." 
        The letter notes several reasons why this proposal is inappropriate, including:

• The fact that it interferes with the confidential business relationships of NVOCC's.
• It increases security risks by requiring that unsecured cargo remain on foreign docks longer.
• Customs provided no support for requiring this information before loading.
• It will cause economic harm to the importer without a commensurate increase in security.
• They are unenforceable in a non-electronic environment.
• The proposal does not comport with the requirements of Section 343, Trade Act of 2002 that authorizes Customs to implement an electronic data interchange system, for information pertaining to "cargo destined for importation into the United States, prior to such importation."
• An international carrier's bond should not be required from an entity other than the vessel operator.
• The regulatory requirements will cause an unreasonable paperwork burden on the public.

• The proposal does not comply with federal requirements regarding the effect of regulatory actions on small businesses.

        In the comments, the various groups noted while, it is expected that some legislation and/or reasonable regulations will be implemented to prevent the importation of weapons of mass destruction, it appears that the proposed regulations will only serve to interdict the smooth flow of legitimate commerce and economically disadvantage United States importers and other entities involved in international trade. They conclude that the proposals should be withdrawn and new proposals drafted in accordance with the recently enacted Section 343 of the Trade Act of 2002." 
        Headquartered in Washington, D.C., the NCBFAA (members.ncbfaa.org) represents over 700 member companies - the nation's leading freight forwarders, customs brokers, ocean transportation intermediaries (OTIs) and air cargo agents. Established in 1897 in New York, NCBFAA is the strong, effective national voice of the industry. Through its various committees, counsel, 30 Affiliated Association offices and representatives, the Association maintains a close watch over legislative and regulatory issues that affect its members. It keeps them informed of these and other related issues through its weekly Monday Morning eBriefing, NCBFAA Quarterly Bulletin, and various meetings, seminars and conferences throughout the year.