Importer Security Filing (ISF)

Importer Security Filing (ISF), or "10+2", is the advance cargo data U.S. Customs and Border Protection requires for cargo arriving in the United States by vessel (19 CFR 149.2(a)): ten data elements from the importer side, most of them due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port, plus two carrier filings, the vessel stow plan and container status messages. Bulk cargo that is exempt from the carrier's 24-hour manifest rule is exempt from the ISF too (19 CFR 149.4(a)), and there is no ISF for air freight.

The 10+2 data elements

The ten importer elements, reported for each good at the six-digit HTSUS level and at the lowest bill of lading level, which is the house bill when there is one (19 CFR 149.3(a)):

1. Seller
2. Buyer
3. Importer of record number (or FTZ applicant number)
4. Consignee number, the US party on whose account the goods are shipped
5. Manufacturer (or supplier)
6. Ship-to party, the first party to receive the goods after customs release
7. Country of origin
8. Commodity HTSUS number, to at least six digits
9. Container stuffing location
10. Consolidator (stuffer)

The "+2" come from the vessel carrier: the vessel stow plan, due no later than 48 hours after the vessel leaves the last foreign port (19 CFR 4.7c), and container status messages (19 CFR 4.7d).

ISF filing deadline

• Elements 1 to 8: no later than 24 hours before the cargo is laden aboard the vessel at the foreign port (19 CFR 149.2(b)(1) and (2)). That is 24 hours before loading, not before sailing
• Stuffing location and consolidator: as early as possible, and no later than 24 hours before arrival at a US port (19 CFR 149.2(b)(3))
• Updates: if any information changes or more accurate information becomes available before the goods arrive, the filer must update the ISF (19 CFR 149.2(d)); if the goods will no longer come to the United States, it must be withdrawn (149.2(e))
• Break bulk cargo exempt from the carrier's 24-hour rule must instead file the ISF no later than 24 hours before arrival (19 CFR 149.4(b))

Who files the ISF

The ISF Importer, the party causing the goods to arrive at a US port by vessel: the goods' owner, purchaser, consignee, or an agent such as a licensed customs broker (19 CFR 149.1). For foreign cargo remaining on board (FROB), the carrier or NVOCC is the ISF Importer. Any agent that has set up CBP's electronic filing connection can transmit the ISF (19 CFR 149.5(a)), and CBP's ISF FAQ confirms the filing agent does not have to be a customs broker, except when the ISF and the entry go in a single combined transmission, which must come from the importer itself or a licensed broker. The agent must keep the importer's power of attorney (149.5(c)).

ISF bond and penalties

The ISF Importer must hold a customs bond (19 CFR 149.5(b)). CBP's ISF FAQ says a stand-alone ISF must be secured by a continuous bond, such as a continuous importation bond, or by a dedicated ISF bond, continuous or single transaction; a single entry bond covers the ISF only when the ISF and the entry go in one combined filing, and then it must be $10,000 higher. The bond's conditions provide for liquidated damages of $5,000 for each violation of the ISF rules (19 CFR 113.62(j)). CBP's ISF FAQ counts an ISF that cannot be matched to a bill of lading as inaccurate.

ISF and AMS

The ISF is the importer's filing. The carrier's cargo declaration, filed through the Automated Manifest System (AMS), is a separate filing, also due 24 hours before the cargo is laden at the foreign port (19 CFR 4.7(b)(2)); an FMC-licensed NVOCC with an international carrier bond may transmit the declaration for its own house bills directly (19 CFR 4.7(b)(3)(i)). The bill of lading number is the link between the two: the ISF must be filed at the lowest bill of lading level transmitted to CBP, so on NVOCC cargo it quotes the house bill, not the master.

Airlift is an FMC-licensed NVOCC (OTI 016162), not a licensed customs broker. It arranges the ISF for the ocean shipments it books, against the same house bill it issues, and licensed customs brokers file the entry. ISF filing service →