Compliance
ISF Filing: Requirements, Deadline and Penalties (10+2)
Everything importers need to know about the Importer Security Filing (10+2).
The Importer Security Filing (ISF), commonly known as "10+2," is a CBP requirement for ocean shipments entering the United States. ISF filing must happen at least 24 hours before cargo is laden aboard a vessel at the foreign port. Failure to comply can result in $5,000 liquidated damages per violation, cargo holds, and intensive examinations. The rules are in 19 CFR Part 149. To have Allied CHB file for you, see our ISF filing service.
What is ISF in customs?
The ISF is an electronic declaration of cargo data. CBP uses it to screen ocean freight before it is loaded for the United States. It is separate from the customs entry: it does not pay duty and does not release the goods.
The "10" are the data elements that the ISF Importer sends. The "+2" come from the ocean carrier: the vessel stow plan (19 CFR 4.7c) and container status messages (19 CFR 4.7d). The ISF Importer is the party that causes the goods to arrive by vessel: the owner, purchaser, consignee, or an agent such as a licensed customs broker (19 CFR 149.1).
When does ISF need to be filed? The ISF filing deadline
The ISF filing deadline is 24 hours before the cargo is laden aboard the vessel at the foreign port (19 CFR 149.2(b)). The clock runs from loading, not from departure or arrival. Two elements may come later.
| Data | Deadline |
|---|---|
| Seller, buyer, importer of record number, consignee number | 24 hours before lading at the foreign port |
| Manufacturer (or supplier), ship-to party, country of origin, HTS number | 24 hours before lading at the foreign port |
| Container stuffing location, consolidator (stuffer) | As early as possible, no later than 24 hours before arrival at a U.S. port (or on lading, if the voyage is shorter than 24 hours) |
| ISF-5 for IE and T&E in-bond cargo | 24 hours before lading at the foreign port |
| ISF-5 for FROB cargo | Before lading at the foreign port |
For the four elements in the second row, CBP accepts the best data available at filing. The filer must update them when better data is known, no later than 24 hours before arrival (19 CFR 149.2(f)).
What are the 10 ISF data elements?
19 CFR 149.3(a) lists them. They are required for each good at the lowest bill of lading level (the house bill, if there is one). The manufacturer, country of origin and HTS number must be linked on each line.
- Seller: the last known seller (if there is no sale, the owner)
- Buyer: the last known buyer (if there is no sale, the owner)
- Importer of record number: IRS number, EIN, SSN or CBP-assigned number
- Consignee number: the U.S. party on whose account the goods ship
- Manufacturer (or supplier): the party that last makes, assembles or grows the goods
- Ship-to party: the first party that receives the goods after CBP releases them
- Country of origin
- Commodity HTS number: at least 6 digits (CBP uses it for the entry only at 10 digits)
- Container stuffing location (for break bulk, where the goods were made "ship ready")
- Consolidator (stuffer): the party that stuffed the container or arranged it
What is an ISF-5 filing?
An ISF-5 covers cargo that passes through a U.S. port but is not imported: foreign cargo remaining on board (FROB), and goods moved in-bond for immediate exportation (IE) or transportation and exportation (T&E). The 5 ISF-5 requirements are booking party, foreign port of unlading, place of delivery, ship-to party and a 6-digit HTS number (19 CFR 149.3(b)).
For FROB, the carrier or NVOCC files before lading. For IE and T&E, the owner, purchaser, consignee, the in-bond filer or a customs broker files 24 hours before lading. If the goods will be entered after all, a new ISF-10 replaces the ISF-5.
Who can file ISF, and how do you file ISF online?
The ISF Importer can file itself or use an authorized agent (19 CFR 149.5). The ISF goes to CBP only through a CBP-approved electronic system: ABI, or the vessel manifest system in ACE. There is no paper ISF.
- To self-file, you need ISF software from an ABI or ocean AMS vendor, and a filer code (ABI filer code or SCAC).
- An agent does not have to be a customs broker. A foreign freight forwarder can file as an agent.
- The agent keeps the power of attorney until it is revoked, and 5 years after (19 CFR 149.5(c)).
- The ISF and the entry can go in one unified transmission (19 CFR 149.6). Only the importer or a licensed broker can send it.
What is the ISF number, and how does bill of lading matching work?
When CBP accepts an ISF, it returns a unique ISF transaction number (the ISF number). A rejected ISF gets no number: the filer corrects it and sends it again as a new filing.
Every ISF must give the bill of lading at the lowest level in ACE: the house bill or the regular bill, never the master bill. The bill number links the ISF to the carrier's manifest. The ISF must match the bill no later than 24 hours before arrival at the first U.S. port, or CBP treats it as inaccurate.
"Accepted, No Bill on File"
CBP accepted the ISF but has no matching bill in ACE yet. Often the carrier has not sent the manifest, and CBP sends a match message later. Check the bill number and bill type. Do not send a replacement ISF only to force a match.
Does an ISF need a customs bond?
Yes (19 CFR 149.5(b)). A continuous importation bond (activity code 1), a custodial, carrier or FTZ operator bond, or an Importer Security Filing bond (Appendix D to Part 113, activity code 16) secures it. If the ISF Importer has no bond, the agent may post its own. As a matter of policy, CBP does not enforce the bond requirement for household goods, government, diplomatic and carnet ISFs.
| Bond | Amount | Notes |
|---|---|---|
| Continuous import bond (activity code 1) | $50,000 minimum | Covers ISF with no rider |
| ISF bond, single transaction (activity code 16) | $10,000 | Sent in ACE eBond within 12 hours after CBP accepts the ISF |
| ISF bond, continuous (activity code 16) | $50,000 minimum | Covers ISF only, not entries |
To size a continuous bond, use the customs bond calculator.
How do ISF updates and withdrawals work?
- Update: if data changes, or better data is known, before the goods arrive, the filer must update the ISF (19 CFR 149.2(d)).
- Sale in transit: update the buyer and other changed fields. Do not delete the ISF and file a new one: CBP can treat it as late.
- Withdrawal: if the goods will not come to the United States, withdraw the ISF and give CBP the reason (19 CFR 149.2(e)).
What are the ISF penalties?
Under 19 CFR 113.62(j), the importer and its surety agree to pay liquidated damages of $5,000 for each ISF violation. The carrier bond has the same amount (19 CFR 113.64(f)). CBP can claim $5,000 per late ISF, per inaccurate ISF, for the first inaccurate update, and for a failure to withdraw.
| Case | Claim | Cancellation on payment of |
|---|---|---|
| First violation | $5,000 | $1,000 to $2,000 |
| Later violations | $5,000 | Not less than $2,500 |
| Law enforcement goals compromised | $5,000 | No relief |
The ISF Importer can petition for relief. Mitigating factors include few violations compared to the number of ISFs, remedial action, a vessel diversion outside your control, and CTPAT Tier 2 or 3 status. If the filer got the data from another party, believed it and could not verify it, CBP may cancel the claim with no payment.
No ISF and no bond
Then CBP cannot claim liquidated damages. Instead, CBP withholds release of the cargo until it receives the ISF, and can examine it. Cargo unladen without permission may be seized. Serious or repeated violations can bring penalties under 19 U.S.C. 1595a(b).
Are bulk and break bulk cargo exempt from ISF?
Bulk cargo is loose in the hold, such as oil, grain, coal or ore, or items handled mechanically such as steel beams (19 CFR 149.1(c)). Bulk cargo exempt from the carrier's 24-hour manifest rule is also exempt from the ISF (19 CFR 149.4(a)).
Break bulk cargo is packaged or bundled but not containerized. If CBP exempts it from the 24-hour manifest rule, the ISF is due 24 hours before U.S. arrival instead (19 CFR 149.4(b)). The ISF applies only to vessel cargo: air and truck shipments need none.
Questions
Is the ISF deadline 24 hours before departure or before arrival?
Neither. The main ISF filing deadline is 24 hours before the cargo is loaded (laden) aboard the vessel at the foreign port. Only the container stuffing location and the consolidator may come later, up to 24 hours before the vessel arrives at a U.S. port. Ask the forwarder for the planned loading date, not only the sailing date.
Can I file an ISF after the vessel has sailed?
Yes, and you must. A late ISF is still required. CBP withholds release of the cargo until it receives the ISF and can examine the goods. The late filing can bring a liquidated damages claim of $5,000. If you bought goods on the water with no ISF, the original ISF Importer stays liable for the late filing.
Is the forwarder or the importer responsible for a late ISF?
The ISF Importer. For goods that you import, that is usually the owner, buyer or consignee. An agent can file for you, but CBP claims the liquidated damages against the bond that secured the ISF: yours, or the agent's if the agent posted it. Agree in writing who sends each element and by when.
Does one ISF cover a container with several house bills?
One ISF can list more than one bill of lading, but each bill must be at the lowest level in ACE. A consolidated container usually has several house bills for different importers. Each importer files its own ISF with its own house bill. The master bill number is never used on the ISF.
Is an ISF required for household goods and personal effects?
Yes, if the goods arrive by vessel. CBP has a separate ISF type for household goods and personal effects, with the same deadlines, and does not require a bond for it as a matter of policy. An IRS number or CBP-assigned number used on this ISF must first be registered with CBP on CBP Form 5106.
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