ISF 10+2: what an importer must file before the ship sails, and what a late filing costs
The ISF is due 24 hours before your container is loaded at the foreign port, not when it arrives. The ten data elements, who files, and what late filing costs.
Short answer: The Importer Security Filing (ISF, or 10+2) is ten data elements about an ocean shipment that the importer must send to CBP at least 24 hours before the cargo is loaded at the foreign port. A late or inaccurate filing exposes the importer's bond to $5,000 in liquidated damages per violation.
The Importer Security Filing (ISF, often called 10+2) is a set of ten data elements about an ocean shipment that the importer sends to U.S. Customs and Border Protection before the container is loaded at the foreign port. The carrier sends two more. The deadline is 24 hours before loading, which means an ISF for a container sailing from Cartagena is due while the goods are still on the dock in Colombia.
Why it matters: the filing runs on data only your supplier has, and it is due days or weeks before the container reaches you. Each late or wrong filing can cost $5,000 under your bond.
What the "10+2" covers
The ISF rule took effect on January 26, 2009, and applies to import cargo arriving in the United States by vessel. The ten importer elements are set out in 19 CFR 149.3:
| # | Element | What it is | Who usually has it |
|---|---|---|---|
| 1 | Seller | Last known entity selling the goods | Your purchase order |
| 2 | Buyer | Last known entity buying the goods | Your purchase order |
| 3 | Importer of record number | IRS, EIN, SSN or CBP-assigned number | You or your broker |
| 4 | Consignee number | Number of the party the goods are consigned to | You or your broker |
| 5 | Manufacturer (or supplier) | Entity that last made, assembled or grew the goods | The supplier |
| 6 | Ship-to party | First party scheduled to physically receive the goods | You |
| 7 | Country of origin | Country of manufacture, production or growth | The supplier |
| 8 | HTSUS number | Tariff classification, at least six digits | You or your broker |
| 9 | Container stuffing location | Where the container was physically loaded | The supplier or forwarder |
| 10 | Consolidator (stuffer) | Party that stuffed the container | The supplier or forwarder |
The "+2" belongs to the carrier: the vessel stow plan, due no later than 48 hours after the ship leaves its last foreign port (19 CFR 4.7c), and container status messages, due within 24 hours of each event being logged in the carrier's tracking system (19 CFR 4.7d). You never file these yourself.
The deadline is at the origin port, not at arrival
The ISF runs on the loading date, not the arrival date. Under 19 CFR 149.2, the elements are due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port.
Illustrative timeline: a container scheduled to load on a Tuesday afternoon needs its ISF transmitted by Monday afternoon, even if the vessel will not reach Miami for another week. A booking that rolls to an earlier vessel moves the deadline with it.
The regulation allows two kinds of flexibility, and neither one extends the original deadline:
- Stuffing location and consolidator can be sent later, but no later than 24 hours before the vessel arrives at a U.S. port.
- Manufacturer, ship-to party, country of origin and HTSUS number can be filed on the best data available, then corrected as better information arrives, again no later than 24 hours before arrival.
After that, the filer must update the ISF whenever any element changes before the goods reach a U.S. port, and withdraw it, with a reason, if the goods are no longer coming.
Who files, and who carries the responsibility
The regulation places the obligation on the ISF Importer, defined in 19 CFR 149.1 as the party causing the goods to arrive by vessel: the owner, purchaser or consignee, or an agent such as a licensed customs broker. In a typical U.S. import, that is you.
A broker can transmit the filing on your behalf. What the broker cannot do is invent the supplier's data or file it before you send it. When the filing is late because the manufacturer's address arrived from the supplier two days after loading, the delay is yours.
The ISF Importer also needs a bond that covers the filing. 19 CFR 149.5 accepts several, including a basic importation and entry bond with the standard ISF provisions or a dedicated ISF bond. If you have none, the agent filing for you may post its own. Bond types and filing arrangements vary, so confirm yours with your customs broker before the first shipment.
What a late or wrong ISF costs
The bond conditions in 19 CFR 113.62 set liquidated damages of $5,000 for each violation of the ISF requirements. CBP also lists increased inspections and cargo delays among the consequences of non-compliance.
An inspection brings costs of its own. A container held for examination sits at the terminal while its free time runs, and the charges that follow are the ones described in demurrage vs detention. An ISF problem at the origin port can turn into a demurrage invoice at the destination port.
| Problem | When it happens | What it can lead to |
|---|---|---|
| Filed after loading | At origin | Liquidated damages; possible inspection or delay |
| Missing element | At origin | Liquidated damages; possible inspection or delay |
| Stuffing location or consolidator never added | Before arrival | Liquidated damages |
| Changed data not updated | Before arrival | Liquidated damages; inspection |
| Goods cancelled, filing not withdrawn | Any time | Liquidated damages |
Where the data comes from, and when to ask for it
Four of the ten elements (seller, manufacturer, stuffing location and consolidator) are known to your supplier or its forwarder before you know them. Asking for them when the booking is confirmed can leave only days. Asking at the proforma leaves weeks.
In the Container Control Method, that makes the ISF data an exit condition of the Proforma stage: the proforma is not closed until the supplier has confirmed who made the goods, where the container will be stuffed and by whom. The filing itself belongs to Shipped, and its confirmation is part of the evidence that the stage happened.
For LCL shipments, the stuffing location and consolidator are usually the consolidator's warehouse at origin, which the supplier may not know until the freight is received there. The later deadline for those two elements covers this case.
What the ISF does not cover
- Air and truck imports. The rule applies to vessel cargo only.
- Exports. A container leaving the United States for Santo Domingo or Barranquilla needs no ISF.
- Bulk cargo, which is exempt.
- Cargo only passing through. Foreign cargo remaining on board, immediate exportation and transportation and exportation shipments use a five-element filing, often called ISF-5.
In practice
Put the ISF deadline on the container record the day the booking is confirmed, calculated from the loading date. Arrival dates are the wrong anchor for this filing.
Ask every supplier for the manufacturer, stuffing location and consolidator details as part of confirming the proforma. A supplier who cannot say where the container will be stuffed is telling you something about the shipment, and it is better to learn that before the vessel is booked.
Keep the filing confirmation, and every update, with the container's other documents. Software that attaches documents to the container, the way Clasto does, makes that a single place to look. The habit matters more than the tool: the ISF is the first deadline in an import, and it arrives before the goods have left the supplier's dock.
Step by step
How to file an ISF on time for an ocean import
- Collect the supplier's data at the proforma. Ask for the seller, manufacturer, stuffing location and consolidator details when you confirm the order, not when the booking is made.
- Confirm who files and under which bond. Decide whether you or your broker transmits the filing, and check that a bond with ISF coverage is in place before the first shipment.
- Send the elements to your filer when the booking is confirmed. The booking gives you the vessel and the loading date, which fixes your deadline: 24 hours before the container is loaded.
- Transmit before the deadline. File on the best data you have. Four elements may be refined later, but every element must be present on time.
- Update before arrival. Add the stuffing location and consolidator, and correct any element that changed, no later than 24 hours before the vessel reaches the U.S. port.
- Keep the confirmation on the container file. Store the filing confirmation and any updates with the container's other documents, so you can show when each element was sent.
Frequently asked
Is the ISF the same as the customs entry?
No. The ISF is a security filing about the shipment, due before the container is loaded abroad. The customs entry comes later, when the goods arrive, and is what releases them and settles duty. You need both.
Does ISF apply to air freight or to exports?
No. The rule covers import cargo arriving in the United States by vessel, so air and truck imports fall outside it, and a container you export to Latin America needs no ISF.
What is an ISF-5?
It is the shorter filing for cargo that passes through a U.S. port without being imported: foreign cargo remaining on board, immediate exportation, and transportation and exportation shipments. It has five elements instead of ten.
How much is the penalty for a late ISF?
The bond that covers the ISF sets liquidated damages of $5,000 for each violation. CBP can also hold the cargo for inspection, and the delay costs its own money at the terminal.
Can my customs broker file the ISF for me?
Yes, a licensed broker or other agent can transmit it. The obligation stays with the ISF Importer, so the data you give the broker, and its timing, are still your problem.