When an importer’s customs broker files a customs entry on behalf of the importer, US Customs uses a unique “importer number” to track that importer’s customs transactions. This number is an essential data element, required as part of every customs entry.
US Customs uses three distinct types of numbers as “importer numbers”:
Employer Identification Number (EIN, or IRS number) – as assigned by the US Internal Revenue Service (IRS) to corporations, partnerships, Limited Liability Companies (LLCs), government agencies, sole proprietorships, and assorted other types of entities.
Social Security Number (SSN) – as assigned by the IRS to individuals. Also used by some individuals operating sole proprietorships, who do not have a separate EIN for their business.
Customs Assigned Number – as assigned by US Customs to persons or other entities which do not have either an EIN or a SSN. This group typically includes individuals and companies that do not reside in the US, and/or do not have a significant business presence in the US, and thus do not need an EIN or SSN.
So long as any of these types of numbers remain valid, and are used at least once within every 12 months for automated customs transactions (such as customs entry filing), they will normally remain as active importer numbers in US Customs’ importer records.
However, those Customs importer records contain a very large number of data files for importer numbers that have accumulated over the years, but are seldom or never used for current transactions. To clean out some of these un-needed electronic records, Customs has recently increased its efforts to identify and invalidate importer numbers that have not been used for automated customs transactions within the last 12 months. When Customs invalidates such an importer number it normally does not notify either the importer, or the importer’s customs broker, of this action.
As a direct result, many infrequent importers – and their customs brokers – have recently been surprised to learn that their importer numbers need to be reactivated, before a current shipment can be cleared through Customs. This becomes especially urgent when a shipment has already arrived at destination, and little or no “free time” remains before storage charges begin.
Normally, the “turn-around time” for Customs to reactivate a voided importer number is at least two business days. The recent Customs emphasis on voiding importer numbers that have not been used during the past 12 months has increased the number of these reactivation requests, and further increased the average time required. The recent partial government shutdown has made this situation substantially more challenging, and recent average “turn-around time” has been about 6 to 7 business days, sometimes longer.
Because the importer’s entry cannot be filed until the importer’s voided importer number is reactivated, and the shipment cannot be released from the carrier’s terminal until the entry has been filed and Customs has authorized the cargo release, some shipments may accumulate as much as a week (or more!) of storage charges, because of a voided importer number.
To avoid this type of potentially costly and inconvenient situation, Transmark Customs Brokers recommends that any infrequent importer, or anyone who has not had at least one customs entry filed for an import shipment within the last 12 months, take these preventive actions:
Notify your customs broker as soon as you decide to order anything that will require an import customs clearance.
Ask the broker to verify whether your importer number is still in active status, in Customs’ importer records.
If your importer number is still active, but it will be more than 12 months since your last entry by the time your new shipment arrives, work pro-actively with your broker to update your customs importer record to keep it active.
Work with your foreign supplier to get copies of the commercial and shipping documents to your broker as early as possible, so the broker can file the entry for your shipment as early as possible.
By getting (and staying!) ahead of US Customs in this area, you can help make the whole importing process less stressful for yourself and reduce the chance of expensive delays and surprises. Transmark Customs Brokers is always available to help you keep yourself “ahead of the game”, and we enjoy helping you do so.