The Importer Security Filing 10+2 rule is a U.S. Customs and Border Protection regulation that requires anyone importing ocean cargo into the United States to electronically submit shipment details before the goods leave the foreign port. The importer provides 10 data elements and the ocean carrier provides 2, which is where the “10+2” name comes from. The filing gives CBP time to flag high-risk shipments before they reach U.S. waters. Skipping it, filing late, or filing inaccurate information can trigger $5,000 in liquidated damages per violation, plus cargo holds at the port.
Who Has to File
The ISF Importer is responsible. That’s typically the U.S. party who owns, purchases, or consigns the goods. The obligation can be handed off to an authorized agent such as a licensed customs broker or freight forwarder, but the legal responsibility stays with the importer of record no matter who physically submits the data.
The rule covers virtually all non-bulk ocean cargo arriving in the United States: containerized shipments, break-bulk cargo, and roll-on/roll-off vehicles. Bulk cargo is fully exempt. CBP defines bulk cargo as homogeneous freight stowed loose in the hold, such as oil, grain, coal, or ore, that gets pumped, dumped, or mechanically handled rather than loaded in containers or packages.
Several other categories fall outside the rule:
- Empty containers and ISO tanks, though carriers still report them through vessel stow plans and container status messages.
- Ship’s spares and equipment intended for the vessel’s own use.
- Domestic cargo, meaning U.S.-origin goods or previously entered foreign goods moving between U.S. ports.
- Cargo laden in the U.S. that goes abroad and returns without being unloaded overseas.
The 10 Elements You File
The importer’s 10 elements are split into two groups with different deadlines. The first eight must reach CBP no later than 24 hours before the cargo is loaded onto the vessel at the foreign port:
- Seller: name and address of the party selling the goods.
- Buyer: name and address of the party purchasing the goods.
- Importer of record number: the IRS number, CBP-assigned number, or foreign trade zone applicant ID.
- Consignee number: the party receiving the goods in the United States.
- Manufacturer or supplier: the entity that made or supplied the goods.
- Ship-to party: the physical destination where the goods will be delivered.
- Country of origin: where the goods were manufactured or produced.
- Commodity HTSUS number: the Harmonized Tariff Schedule classification.
The remaining two elements must be submitted as early as possible and no later than 24 hours before the vessel arrives at a U.S. port:
- Container stuffing location: where the goods were physically loaded into the container.
- Consolidator: the party that stuffed or loaded the container.
Flexible Elements
Four of the importer’s elements are treated as “flexible.” You can submit your best available information at the initial filing and update it later as details firm up. These four are manufacturer or supplier, ship-to party, country of origin, and commodity HTSUS number. The flexibility isn’t open-ended. You must finalize them no later than 24 hours before the vessel arrives at a U.S. port. For voyages shorter than 24 hours, the cutoff is the moment cargo is loaded at the foreign port.
The Carrier’s 2 Elements
The ocean carrier separately provides a vessel stow plan showing where every container sits on the ship, plus container status messages that track events like loading, unloading, and repositioning. These aren’t part of the importer’s filing. Bulk cargo is exempt from both carrier requirements as well.
When the Filing Is Due
For most containerized cargo, the first eight importer elements must reach CBP at least 24 hours before loading at the foreign port, and the last two must arrive at least 24 hours before the ship reaches a U.S. port.
Break-bulk cargo runs on a different clock. If the break-bulk shipment is exempt from the carrier’s 24-hour advance cargo declaration requirement, the importer is also exempt from filing 24 hours before loading. Instead, the ISF must be presented to CBP at least 24 hours before the cargo arrives in the United States. Any containerized cargo on the same shipment still follows the standard loading deadline.
ISF-5 for Cargo Just Passing Through
Not everything entering U.S. waters is staying. Shipments moving as foreign cargo remaining on board (FROB), immediate exportation (IE), or transportation and exportation (T&E) still need an ISF, but only five elements: booking party, foreign port of unlading, place of delivery, ship-to party, and commodity HTSUS number. This shorter version is commonly called the ISF-5. The 24-hour-before-loading deadline still applies.
How to Submit and the Bond You Need First
All ISF submissions go through CBP’s electronic systems: the Automated Broker Interface (ABI), which is part of CBP’s Automated Commercial Environment (ACE), or ACE itself. Most importers work through a licensed customs broker or a third-party software vendor rather than filing directly, since connecting to ABI requires technical setup and certification.
After CBP receives a valid submission, the system returns a confirmation. That confirmation does not mean CBP has cleared the shipment. It means the filing was accepted for processing. CBP can still flag cargo for examination or issue a hold based on its risk assessment.
You also need an active customs bond in place before filing. Most importers use either a continuous bond, which covers all shipments for a 12-month period, or a single-entry bond for one-off imports. A continuous bond is calculated at 10 percent of duties, taxes, and fees paid over the prior 12 months, with a minimum of $100. A single-entry bond generally must cover at least the total entered value of the goods plus any duties and fees. For importers who ship regularly, a continuous bond is almost always more cost-effective.
Updating or Withdrawing a Filing
ISF isn’t file-it-and-forget-it. If any information changes after you submit and before the goods arrive at a U.S. port, you have to update it, whether that’s a changed consignee or a corrected HTSUS number. CBP expects updates as soon as more accurate information becomes available.
An inaccurate update can trigger the same $5,000 liquidated damages penalty as a late or inaccurate original filing. If a shipment is cancelled or diverted and won’t arrive in the United States, you need to formally withdraw the ISF. Failing to withdraw when required is a separate violation.
Penalties for Getting It Wrong
CBP can assess $5,000 in liquidated damages for each ISF violation. That figure applies per occurrence, whether the violation is a late filing, an inaccurate filing, an inaccurate update, or a failure to withdraw a cancelled ISF. Multiple violations on the same shipment can stack, so a filing that is both late and inaccurate can generate more than one penalty.
First-time violators have some room to negotiate. CBP’s mitigation guidelines allow a first violation to be reduced to between $1,000 and $2,000 if law enforcement goals weren’t compromised. Subsequent violations can be mitigated to no less than $2,500. Reduced amounts aren’t automatic. You have to petition for relief and demonstrate mitigating factors.
Beyond the dollar penalties, non-compliance can result in cargo holds. CBP may detain shipments at the port until the violation is resolved, and those delays generate their own costs. Demurrage fees from the terminal and detention charges from the shipping line add up quickly, sometimes exceeding the penalty itself. For importers with tight supply chains, the operational disruption often hurts more than the fine.