ISF 10+2 Filing Guide: Importer Security Filing Requirements Explained
What Is ISF 10+2?
Importer Security Filing (ISF), commonly called “ISF 10+2,” is a US Customs and Border Protection (CBP) advance cargo information requirement for ocean shipments destined for the United States. The rule requires the importer to submit 10 data elements and the ocean carrier to submit 2 data elements before vessel loading at the foreign port.
ISF was implemented by interim final rule on November 25, 2008 (73 FR 71730) and made fully enforceable on May 13, 2015. The legal authority is the Security and Accountability for Every (SAFE) Port Act of 2006, which directed CBP to obtain advance information sufficient to identify high-risk shipments before they reach the US.
The regulatory text appears at 19 CFR 149. Official guidance and the ISF data dictionary are published at cbp.gov/border-security/ports-entry/cargo-security/importer-security-filing-102.
When Does ISF Apply?
ISF applies to all cargo arriving in the United States by ocean vessel. It does not apply to air freight, truck shipments, or rail shipments. Within ocean cargo, ISF applies in different forms depending on whether the goods are intended for US consumption or are merely transiting through the US.
ISF-10 (full filing): Required for all goods imported into the United States or destined for a US Foreign Trade Zone. Must be filed by the ISF Importer.
ISF-5 (reduced filing): Required for Freight Remaining on Board (FROB), Immediate Exportation (IE), and Transportation and Exportation (T&E) shipments that pass through the US without entering commerce. Five elements instead of ten.
Carrier 2 elements: Required from the ocean carrier on every covered shipment, separately from the importer’s ISF-10 or ISF-5.
Filing Deadlines
Timing is the most important compliance element of ISF. Late filings draw automatic penalties.
ISF-10: Must be filed no later than 24 hours before the cargo is laden aboard the vessel at the foreign port. The deadline is measured against vessel loading, not departure or arrival.
ISF-5: Must be filed before the cargo is laden aboard the vessel at the foreign port (no minimum lead time, but must precede loading).
Carrier 2: Must be filed no later than 24 hours after the cargo is laden, except for vessel stow plans which must be filed 48 hours after departure (or before US arrival for shorter voyages).
Updates and corrections: ISF can be updated until the cargo arrives at the first US port. Updates filed after arrival are not accepted in the same filing and must be handled through ACE.
The 10 Importer Data Elements
The ISF Importer (or its filing agent) must provide the following 10 data elements per shipment.
1. Seller name and address. The party in the foreign country that sold the goods. This is the legal seller, not necessarily the manufacturer or shipper.
2. Buyer name and address. The party in the United States that purchased the goods. This is the legal buyer, typically the IOR.
3. Importer of Record (IOR) number. The IRS EIN, Social Security Number, or CBP-assigned number of the party responsible for entry.
4. Consignee number(s). The IRS EIN of the party in the US to which the goods will be delivered. Multiple consignees can be reported.
5. Manufacturer (or supplier) name and address. The party that physically produced the goods, or in case of distribution, the supplier from whom the seller acquired them.
6. Ship to name and address. The first deliver-to party in the United States after release from CBP custody.
7. Country of origin. The country of manufacture, production, or growth of the goods, determined under non-preferential rules of origin (19 CFR 102).
8. Commodity HTSUS number. The Harmonized Tariff Schedule of the United States classification at the 6-digit level (10-digit is acceptable and preferred).
9. Container stuffing location. The physical address where the cargo was stuffed into the container. Often a different address from the manufacturer or seller.
10. Consolidator (stuffer) name and address. The party that stuffed the container or arranged for stuffing. For containerized cargo, this is critical.
The 2 Carrier Data Elements
The ocean carrier (or NVOCC for cargo loaded under its bill of lading) provides two additional elements.
1. Vessel stow plan. A detailed map of cargo loaded on the vessel, identifying every container by Bill of Lading number and stowage location. Filed for vessels loading at foreign ports destined for the US.
2. Container status messages (CSM). Standardized electronic messages reporting container movements (gate-in, loaded, discharged, gate-out, etc.). Required for all containers en route to or in the US.
Who Files ISF?
The ISF Importer is the party legally responsible for filing the ISF-10. The ISF Importer is not necessarily the same as the IOR.
For goods imported for consumption: The ISF Importer is the goods’ owner, purchaser, consignee, or agent (such as a licensed customs broker or freight forwarder authorized to file).
For FTZ admissions: The ISF Importer is the party with the right to make entry of the goods into the FTZ.
For FROB/IE/T&E: The ISF Importer is the carrier or party with the right to make entry under the in-bond procedure.
Most ISF-10 filings are submitted by the importer’s licensed customs broker or freight forwarder using their CBP-assigned filer code through the Automated Broker Interface (ABI) or AMS.
Bond Requirements
ISF requires a bond to secure the duty obligation in the event of late filing or non-filing penalties.
Continuous Bond: Importers with an active continuous bond (typically used for ongoing entry filings) can use the same bond to cover ISF. CBP automatically calculates ISF coverage.
Single Transaction ISF Bond: Importers without a continuous bond can purchase a single transaction bond covering only the ISF requirement, separate from the entry bond. Cost is typically $50-150 per filing.
Appendix D bond: ISF Importers using a customs broker may rely on the broker’s bond, with the importer named as principal.
Penalties for Late or Inaccurate ISF
CBP enforces ISF compliance through liquidated damages of $5,000 per violation, with a maximum of $10,000 per filing for multiple violations of the same ISF.
Common violation categories:
1. Late ISF filing (not 24 hours before loading)
2. Inaccurate or incomplete ISF data
3. Failure to update ISF when information changes
4. Failure to match ISF to entry data
Mitigation: First-time violators or those with substantial mitigating circumstances can request mitigation under CBP guidelines, often resulting in reduced penalties of $1,000-2,500. Repeat or willful violators face the full $5,000 per violation plus heightened CBP scrutiny on subsequent shipments.
Beyond monetary penalties, severe or repeated ISF non-compliance can trigger a “do not load” order, preventing cargo from being loaded at the foreign port until the violation is resolved.
ISF Progress Reports and Hold Indicators
CBP processes ISF data through the Automated Targeting System (ATS) and assigns risk scores to every shipment. Importers receive feedback through the Automated Broker Interface.
Status responses:
1. Accepted: ISF filing is complete and matches CBP records
2. Accepted with Warnings: filed but contains soft data issues
3. Rejected: missing required fields, must be refiled
4. Hold for Examination: cargo flagged for CBP exam
5. Do Not Load: severe risk indicators, cargo cannot be loaded
Importers should monitor ISF responses through their broker and resolve any hold or rejection before vessel loading to avoid carrier disruption fees.
Frequently Asked Questions
Does ISF apply to LCL (Less than Container Load) shipments?
Yes. ISF applies to all ocean shipments regardless of whether the cargo fills a full container. The NVOCC or freight forwarder typically files ISF for LCL importers using the house bill of lading.
What if my supplier cannot provide ISF data 24 hours before loading?
ISF-Lite or flexible ISF processes are not available. Importers must structure supplier relationships to obtain timely data. Many importers require supplier ISF data submission as a condition of payment.
Are bulk shipments subject to ISF?
Bulk cargo (oil, grain, ore, etc.) is exempt from the ISF-10 filing requirement under 19 CFR 149.4. Break-bulk cargo (loose pieces in vessel hold) is subject to ISF.
Does ISF apply to goods returning to the US?
US Goods Returned (HTS 9801) shipments are subject to ISF. The country of origin and other elements still must be reported even though the goods are not new imports.
Can ISF data be shared with other entities?
ISF data is confidential under 19 U.S.C. 1431(c) and is shared only with CBP and authorized federal agencies. It is not used for commercial market intelligence.
How ExFreight Files ISF for US Importers
ExFreight’s licensed US customs brokerage filers handle ISF-10 submissions for all ocean shipments, automatically populating data from booking confirmations and validating each element against CBP edit rules. ISF is filed in advance of the 24-hour deadline, with status responses tracked and any holds resolved before vessel loading.
Get an instant ocean freight rate from any global origin with integrated ISF filing service at exfreight.com/get-a-quote.
