CBP Form 7512 In-Bond — Filing Rules, Deadlines & the Bond

Under 19 CFR 18.1(a), transporting merchandise in-bond means moving imported merchandise, secured by a bond, from one port to another before appraisement and without paying duties. The in-bond application consists of a transportation entry and a manifest, the two parts the Form 7512 title describes.

What changed is the medium. The application must be transmitted to CBP through a CBP-approved electronic data interchange system (19 CFR 18.1(d)(2)). CBP's in-bond FAQ states that the paper 7512 has been eliminated except for merchandise moved by pipeline and truck shipments transiting the United States from Canada. CBP still publishes Form 7512, its 7512A continuation sheet and a 7512B United States – Canada Transit Manifest sample, but for most truck moves the electronic record is the in-bond.

19 CFR 18.1(b) lists the transportation entries used for in-bond movements. The three a highway carrier meets most are:

Immediate transportation (IT) moves merchandise from the port of arrival to a US port of destination, where it is entered.

Transportation and exportation (T&E) moves merchandise through the United States to a port of exportation, where it leaves the country.

Immediate exportation (IE) exports the merchandise from the port where it arrived.

For T&E and IE, the application names the port of exportation and the first foreign port; for IT, it names the US port of destination (19 CFR 18.1(d)(1)(vi)). Merchandise in transit through the United States between two points in Canada or Mexico also has rules in 19 CFR part 123, so check that part for those moves.

A transportation entry may be filed by the carrier that brings the merchandise to the origination port, the carrier that accepts it under its bond for the in-bond move, or any person with a sufficient interest in the merchandise, each directly or through an authorised agent (19 CFR 18.1(c)). In practice a customs broker often files, but the bond obligated is what decides liability.

Moving merchandise in-bond requires a custodial bond on CBP Form 301 containing the conditions in 19 CFR 113.63 (19 CFR 18.1(e)). The merchandise must be delivered to a carrier bonded for that purpose, and a bonded carrier that uses another carrier's equipment remains responsible for the merchandise (19 CFR 18.2(a)(1)). This custodial bond is what people usually mean by a "7512 bond".

1. File before departure. The in-bond application may be submitted at any time before the merchandise leaves the origination port (19 CFR 18.1(d)(3)).
2. Wait for movement authorisation. CBP must authorise the movement, and it transmits that authorisation electronically (19 CFR 18.1(f)).
3. Keep the record current. Updates and amendments are due within two business days of the event that requires them. If the seal number is not known at filing, add it within two business days of the initial carrier taking possession of the sealed merchandise (19 CFR 18.1(d)(1)(v) and (h)).
4. Divert only with approval. A change of port of destination or exportation needs a diversion request and CBP permission through EDI. If the request is denied, the merchandise goes to the original port (19 CFR 18.5(a)).
5. Deliver within 30 days. Delivery to CBP at the port of destination or exportation is due within 30 days (60 days when a barge is used) from conveyance arrival at the origination port or from CBP's movement authorisation, whichever is later. Neither a diversion nor a new in-bond application extends that period (19 CFR 18.1(i)).
6. Report arrival within two business days. Notify CBP electronically within two business days after any portion of the shipment arrives, including the FIRMS code for where the merchandise sits in the port (19 CFR 18.1(j)).
7. Enter, export or admit within 15 days. The merchandise must be entered, exported or admitted to a foreign-trade zone within 15 calendar days of the entire shipment arriving; on the 16th day it becomes subject to general order (19 CFR 18.1(k)). After a T&E or IE export, the in-bond record must be updated within two business days (19 CFR 18.7(a)(3)).

CBP's in-bond FAQ describes two electronic routes: ACE, and QP/WP, an ABI-hosted in-bond system that lets carriers and non-carriers file in-bond applications and report arrival and export. QP is the application function and WP is the arrival and export function.

For truck shipments, CBP explains that a QP in-bond filed by a customs broker can link to the carrier's ACE e-Manifest shipment released as PAPS when both report the same Shipment Control Number. The carrier then receives a "QP on File" notice. A carrier can also link an unassociated in-bond to a trip in the ACE portal or by EDI. Agree with your broker, before the truck rolls, who files the in-bond and who reports arrival.

Late delivery, or failing to report the arrival or the FIRMS code within the required period, is an irregular delivery (19 CFR 18.1(i) and (j)). The party whose bond is obligated is liable for breaches, including shortages, irregular delivery, non-delivery and unauthorised seal removal, and may be assessed liquidated damages. A petition for relief can be filed under 19 CFR part 172 (19 CFR 18.8).

Keep the in-bond number, authorisation, seal numbers, arrival report and export evidence together with the shipment record. BorderPro early access does not currently transmit in-bond applications, arrivals or exports to CBP; file them through ACE, the ABI QP/WP system or your customs broker. This guide is general information, not legal advice.