How to Fill Out and Submit the ISF Form: Importer Security Filing

To fill out and submit the ISF form, an importer of record (or a licensed customs broker acting under a power of attorney) collects ten data elements from the commercial invoice, purchase order, packing list, and bill of lading, then transmits them electronically to Customs and Border Protection through the Automated Broker Interface or the Automated Commercial Environment at least 24 hours before the container is loaded onto the vessel at the foreign port. The Importer Security Filing, known informally as the “10+2 rule,” applies to containerized ocean freight bound for the United States and is governed by 19 CFR Part 149.¹

Before You File: Who Is Responsible and What Has to Be in Place

The ISF Importer is the party legally on the hook for the filing. That is usually the owner or purchaser of the goods, or a licensed customs broker filing on their behalf with a power of attorney on file. Most importers hire a broker; if the ISF is combined with the entry or entry summary in a single electronic transmission, the filer must be either the importer acting on its own behalf or a licensed customs broker.² Broker fees for an ISF-only filing generally run around $50 to $55.

A customs bond has to be on file before any ISF can be transmitted. The regulation accepts several types: a basic importation and entry bond, a basic custodial bond, an international carrier bond, a foreign trade zone operator bond, or a dedicated ISF bond. If the ISF Importer doesn’t have the right bond, the agent filing on their behalf can post the agent’s own bond instead.² Continuous bonds cover all filings and entries within one year; single-transaction ISF bonds are pegged to the $10,000 maximum exposure per filing.

The Ten Importer Data Elements and Where to Find Them

Shipments entering U.S. commerce (including deliveries to a foreign trade zone) require an ISF-10. Eight of the ten elements come from your own shipping paperwork; the last two — container stuffing location and consolidator — often aren’t known until later and get their own deadline. Here is what each field asks for:³

Seller. Name and address of the party selling the goods. If the goods aren’t being purchased, use the owner’s name and address. A widely recognized commercial identification number can substitute.
Buyer. Name and address of the party buying the goods, with the same owner-substitution and ID-number options as the seller field.
Importer of record number. The IRS number, EIN, SSN, or CBP-assigned number of the party liable for duties. For goods headed to a foreign trade zone, use the number of the party filing the FTZ documentation.
Consignee number. The IRS number, EIN, SSN, or CBP-assigned number of the U.S. person or firm on whose account the merchandise is shipped.
Manufacturer or supplier. Name and address of the entity that last manufactured, assembled, produced, or grew the goods, or the party supplying the finished goods from the country of export. The manufacturer identification (MID) format already used for entry purposes is also accepted.
Ship-to party. Name and address of the first party scheduled to physically receive the goods after customs release.
Country of origin. The country where the goods were manufactured, produced, or grown, determined under U.S. import rules.
Commodity HTSUS number. The Harmonized Tariff Schedule classification for the goods, used for duty and statistical reporting.
Container stuffing location. Name and address of the physical location where the goods were loaded into the container.
Consolidator. Name and address of the party that stuffed the container or arranged for it to be stuffed.

The carrier separately submits a vessel stow plan and container status messages. Those are the “+2” and are not your responsibility as the importer.⁴

If the Cargo Isn’t Entering U.S. Commerce

Foreign Remaining on Board (FROB) shipments and goods moving through the country under Immediate Exportation or Transportation and Exportation procedures use a streamlined ISF-5 with only five fields: booking party, ship-to party, foreign port of unlading, place of delivery, and commodity HTSUS number.⁴ Since the goods never enter the domestic market, there is no seller, buyer, importer of record, or consignee to report. The data typically comes from the master bill of lading or other transit documentation.

When Each Element Is Due

All required data must reach CBP no later than 24 hours before the cargo is loaded onto the vessel at the foreign port.⁴ That window is what allows CBP to screen the shipment and, if something looks wrong, issue a “do not load” order before the container ever moves.

Four elements are treated as flexible: manufacturer or supplier, ship-to party, country of origin, and commodity HTSUS number. You can submit your best available information on those four at the 24-hours-before-loading deadline and refine them later, but the final versions must be on file no later than 24 hours before the vessel arrives at the first U.S. port.¹ For a voyage shorter than 24 hours, those updates are due by the time of lading at the foreign port.

The two container-related elements — stuffing location and consolidator — must be submitted as early as possible but no later than 24 hours before the vessel arrives at the U.S. port.⁴ The other six elements do not get this cushion.

Transmitting the Filing and Confirming It Landed

Every ISF has to be sent electronically through ABI or ACE.⁴ There is no paper form and no email submission. Once CBP accepts the transmission, the system returns a unique ISF Transaction Number. Match that number against the bill of lading to make sure the shipment is correctly linked in CBP’s manifest system.

Filings are matched at the lowest bill of lading level recorded in the vessel manifest — either a house bill or a straight bill of lading. A single ISF can cover multiple bills as long as they belong to the same shipment, the same importer of record, and the same vessel and voyage.⁵ If the ISF and the manifest don’t line up, the cargo can sit at the terminal until the discrepancy is fixed.

Updating or Correcting After You File

If any information changes after submission — a new ship-to party, a corrected HTSUS classification, an updated manufacturer — you are required to update the filing as soon as more precise data is available.¹ Updates run through the same ABI or ACE channels as the original.

The four flexible elements can be refined up until 24 hours before U.S. arrival. Corrections to the non-flexible elements (seller, buyer, importer of record number, and consignee number) don’t have that window and should be sent as quickly as possible. When a party can’t independently verify information received from a supplier or forwarder, the regulation allows filing what the party “reasonably believes to be true.”⁶

What a Bad Filing Costs

Liquidated damages for an inaccurate, incomplete, or late ISF are $5,000 per violation, with maximum exposure of $10,000 per filing.⁴⁵ Money is only part of it. CBP can issue a “do not load” order that keeps the container off the ship, place domestic holds that lock the cargo on the terminal after arrival, or order a physical exam. If no bond is in place, CBP cannot assess liquidated damages, but it can still withhold release of the cargo until the information is filed and reviewed.

A note on scope: the ISF requirement applies only to vessel cargo. Air, truck, and rail shipments do not need one, and the exemption is based on cargo type rather than value — even a low-value informal entry moving by ocean still requires a filing.

Most ISF problems trace back to slow information from overseas suppliers. Start collecting the commercial invoice, packing list, and purchase order details well before the container reaches the foreign loading port. Locking in your data early is the difference between a clean filing and scrambling to correct one with the vessel already at sea.

1
eCFR. 19 CFR Part 149 – Importer Security Filing
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eCFR. 19 CFR 149.5 – Eligibility, Bond Requirements, and Powers of Attorney
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eCFR. 19 CFR 149.3 – Importer Security Filing – Loss Elements
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U.S. Customs and Border Protection. Import Security Filing (ISF) – When to Submit to CBP
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U.S. Customs and Border Protection. Importer Security Filing and Additional Carrier Requirements
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U.S. Customs and Border Protection. Guidelines for the Assessment and Cancellation of Claims for Liquidated Damages for ISF Requirements