Comment Submitted by Anonymous

I do not see how 10+2 has been approved by the WTO: Reference to the following: The WTO, Appellate Body, 1998. Appellate Body Report WT/DS58/AB/RR. "United States- Import Prohibition of Certain Shrimp and Shrimp Products" "...It may be quite acceptable for a government, in adopting and implementing a domestic policy, to adopt a single standard applicable to all its citizens throughout that country. However, it is not acceptable, in international trade relations, for one WTO Member to use an economic embargo to require other Members to adopt essentially the same comprehensive regulatory program, to achieve a certain policy goal, as that in force within that Member's territory, without taking into consideration different conditions which may occur in the territories of those other Members." Furthermore, if U.S. importers are required to transmit the additional data elements, what will be the method of transmission? I realize customs is looking into current CBP-approved electronic data systems for the actual transmission of the data. This includes AMS (Automated Manifest System), ABI (Automated Broker Interface), and the standard systems for transmitting Container Status Messages (ANSI X.12 & EDIFACT). However, before publicizing a mandate, it would be nice to know how we are to follow and comply. Ironically, there is still a mystery on the approved method of transmission. Will the information be accessible through ACE or what other portal will be the repository? Lastly, there is also on the table the 100% screening rule? 100% inspection prior to export is a unrealistic expectation. How will each foreign port install such scanning equipment and who will pay ? I envision a shortage of scanning equipment and those that know how to operate it. Will we in return scan our cargo for export to the rest of the world?