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As president of Global Data Mining, I have the opportunity to speak daily with a broad range of clients from many diverse industries, all involved in international trade.

On January 2, 2008, U.S. Customs & Border Protection (CBP) published in the Federal Register a notice of proposed rulemaking for Importer Security Filing and Additional Carrier Requirements, commonly known as "10+2." Since then, I've watched companies react to 10+2 in three distinct ways.

A very small minority of our clients have responded by funding a cross-functional team to study the issue and develop an enterprise-wide strategic solution to meet the new requirements and optimize global trade business processes while they are at it. These best-in-class companies are way ahead of the 10+2 curve.

I have noticed the remaining companies seem to fall into one of two groups. There are companies heading full speed for a cliff and completely unaware of it…and there are companies heading full speed for the same cliff, but at least they are aware of it.

The "aware" group has a chance to use this dramatic change in customs regulations as a catalyst for process improvement and to remain competitive with the best-in-class group. I fear any companies that remain unaware will suffer mightily when 10+2 goes into effect.

The reason even "aware" companies are heading toward disaster is while their leadership may be alert to the newly proposed customs regulations they mistakenly believe it can be managed tactically by their trade compliance department, when in actuality it will require an enterprise-wide strategic solution.

It is important for senior management of U.S. importers to understand the significant impact 10+2 can bring to their companies and develop an enterprise-wide strategy to prepare for it.