When the 10+2 Importer Security Filing interim final rule was announced in November, those who opposed its issuance in the first place could take some, but perhaps not much, comfort in Customs' decision to conduct a review this year of the data elements to determine which if any should be dropped.

Homeland Security said it will "conduct a review to determine any specific compliance difficulties that importers and shippers may experience in submitting all 10 data elements, 24 hours before lading. Based upon the analysis, DHS will determine whether to eliminate, modify or maintain these requirements."

With the importing public figuring out how to gather all the data elements, not knowing if any will get dropped, the question is coming up whether any of them in fact will be. Some say that those hoping for changes shouldn't get their hopes up.

"They have said all along that after analyzing hundreds of data elements they came down to these 10, so they are going to fight it tooth and nail" to keep them in place, said Terrance O'Neill, vice president for compliance at Maersk Customs Services.

He spoke yesterday on a 10+2 webcast held within the JoC 10+2 Information Center and Virtual Trade Show. (For login information, click here).

I agree with Terry's statement. Getting the rule implemented over pitched opposition from influential business groups such as the National Association of Manufacturers was not easy, especially with the recession gathering steam last fall. The Office of Management and Budget needed to sign off, and it wasn't always clear if that would happen with the White House being bombarded with letters and visits from opponents.

DHS also needs ammo to show Congress that container security won't vanish if unrealistic laws such as 100 percent scanning don't get implemented, as Secretary Janet Napolitano suggested last month.

So advice to importers: don't hold back in implementing 10+2 on the idea that you won't have to collect some of the data elements. You may find yourself unprepared when Customs starts enforcing the law next Jan. 26.