ISF 10+2 Explained: Importer Security Filing Rules for Ocean Shipments to the US
If you ship ocean containers to the US, someone must file an Importer Security Filing (ISF) with US Customs and Border Protection (CBP) before the goods are even loaded in China. A late or wrong ISF can mean holds, exams and a bond claim. Here is what the rule requires, who is responsible, and how to stay compliant, based on the regulation itself.
What ISF is and when it applies
ISF, often called "10+2," is set out in 19 CFR Part 149. Under § 149.2, it applies to cargo arriving in the US by vessel, except bulk cargo, and it must be submitted in English through a CBP-approved electronic system. The "10" are data elements the importer provides; the "+2" (vessel stow plan and container status messages) come from the ocean carrier. ISF does not apply to air freight, express parcels or truck shipments.
Compliance has been required since January 26, 2010, according to § 149.2(g).
Who is the "ISF Importer"
Section 149.1 defines the ISF Importer as "the party causing goods to arrive within the limits of a port in the United States by vessel." For goods entering the US, that is normally the owner, purchaser or consignee, or an agent such as a licensed customs broker. In practice, many Chinese sellers ask their freight forwarder or US broker to file. You can delegate the filing, but your company remains responsible for the data, so give your agent accurate information early.
The 10 data elements and their deadlines
According to § 149.2(b) and § 149.3(a), the importer must provide these elements:
| # | Data element | Deadline |
|---|---|---|
| 1 | Seller | 24 hours before loading at the foreign port |
| 2 | Buyer | 24 hours before loading |
| 3 | Importer of record number / FTZ applicant ID | 24 hours before loading |
| 4 | Consignee number(s) | 24 hours before loading |
| 5 | Manufacturer (or supplier)* | 24 hours before loading |
| 6 | Ship-to party* | 24 hours before loading |
| 7 | Country of origin* | 24 hours before loading |
| 8 | Commodity HTSUS number (6-digit minimum)* | 24 hours before loading |
| 9 | Container stuffing location | As early as possible, no later than 24 hours before US arrival |
| 10 | Consolidator (stuffer) | As early as possible, no later than 24 hours before US arrival |
* Under § 149.3(a), the manufacturer, country of origin and HTSUS number must be linked to each other at the line-item level. The HTSUS number must be provided to at least six digits; it can be used for entry only if given at 10 digits by the importer of record or its licensed broker.
Four elements (manufacturer, ship-to party, country of origin and HTSUS number) may first be filed as "best available data" under § 149.2(f), but must be updated no later than 24 hours before the vessel arrives in the US.
Updates, withdrawals and penalties
- Update: if any information changes or more accurate data becomes available before the goods arrive, § 149.2(d) requires you to update the filing.
- Withdraw: if the goods will no longer be imported into the US, § 149.2(e) requires you to withdraw the ISF.
- Bond liability: the basic importation bond conditions in 19 CFR 113.62(j) state that if the principal defaults on ISF obligations, liquidated damages of $5,000 for each violation may be claimed.
The $5,000 figure is the bond amount set in the regulation. How CBP enforces it in any specific case can vary; check with your licensed customs broker.
Practical checklist for sellers
- Get an importer of record number and a bond. The number is usually an IRS/EIN number. Section 149.5(b) requires the ISF Importer to hold a bond, such as a basic importation and entry bond or a dedicated ISF bond; arrange it before your first shipment.
- Agree who files. Put it in writing with your forwarder or broker, including how they will receive data and confirm acceptance.
- Collect data from the factory early. Get the full manufacturer name and address, stuffing location and consolidator before booking, not after the container is loaded.
- Classify first. Confirm HTS codes before shipment; see how to find your HTS code. Make sure country of origin matches your product marking (country-of-origin marking rules).
- Use the house bill of lading level. Section 149.3(a) requires data at the house bill level, so for consolidated (LCL) cargo each house bill needs its own correct data.
- Keep FBA/3PL addresses correct. The ship-to party is the first place that will physically receive the goods after customs release, often a deconsolidation warehouse or 3PL, not the final Amazon FC.
- Update before arrival. If your supplier, stuffing location or HTS code changes, update the ISF before the vessel arrives.
Common mistakes
- Listing the trading company as manufacturer when the regulation asks for the party that last manufactures or assembles, or the supplier of finished goods.
- Filing after loading because the forwarder only received the packing list at the port.
- Reusing an old ISF template after changing factories.
- Forgetting to withdraw a filing when a shipment is cancelled.
How Atronia Innovations helps
Our Los Angeles and Shenzhen teams help factories and brands get product data, HTS classification and marketplace listings consistent before goods ship, so customs and channel launches stay on schedule. Once stock lands, we offer discounted US last-mile labels. See our logistics services or contact us.
