Demystifying ISF Submission for Foreign Subsidiaries: A Comprehensive Guide

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In summary, the ISF submission process for foreign subsidiaries in customs brokerage involves several key considerations. First, it is crucial to understand the concept of a foreign subsidiary, which is a company controlled or owned by a parent company in another country. The ISF submission itself is a mandatory requirement by US Customs and Border Protection (CBP) for ocean shipments entering the United States.

When it comes to foreign subsidiaries, the CBP requires that the ISF be filed by the party with the lowest bond sufficiency. This means that if the parent company already has a continuous bond that covers the activities of the subsidiary, the ISF can be filed by the parent company on behalf of the subsidiary. However, the parent company needs to provide written authorization to the CBP, designating the foreign subsidiary as its agent for ISF filing.

During the ISF submission process, it is important to accurately represent the foreign subsidiary as the "Importer of Record" on the ISF filing. This means that all the information provided should reflect the details of the foreign subsidiary and not the parent company. Effective communication and coordination between the parent company and the foreign subsidiary are essential to ensure timely sharing of shipment information and relevant documentation.

Additionally, each foreign subsidiary should have its own unique bond in place, separate from the parent company's bond. This subsidiary bond serves as a backup to the parent company's bond and provides additional coverage specifically for the subsidiary's activities.

In conclusion, the ISF submission process for foreign subsidiaries in customs brokerage requires proper authorization, accurate representation of the subsidiary as the "Importer of Record," effective communication, and coordination between the parent company and the subsidiary, and the existence of a separate bond for the subsidiary. These considerations ensure a smooth process and compliance with CBP requirements.
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