ISF 10+2 Form: Data Elements, Deadlines, and Penalties

The ISF 10+2 filing requirements apply to anyone importing ocean freight into the United States: the importer must electronically transmit 10 shipment data elements to U.S. Customs and Border Protection at least 24 hours before the cargo is loaded onto the vessel at the foreign port, and the vessel carrier separately transmits 2 more. Late, inaccurate, or incomplete filings can draw liquidated damages of $5,000 per violation, capped at $10,000 per ISF, plus cargo holds and additional inspections at the U.S. port.¹

Who Files and Who’s Responsible

The ISF Importer is the party legally on the hook for the 10 elements. That’s usually the Importer of Record, meaning whoever owns or bought the goods and is liable for duties. You don’t have to transmit the data personally. The regulation lets you authorize a licensed customs broker to submit it for you, and most importers do exactly that.²

The vessel operating carrier is responsible for the other two elements, the stow plan and container status messages. You have no control over the carrier’s side, but a gap or mismatch there can still hold up your cargo, so it pays to confirm your broker is watching the manifest as well as the ISF.

The 10 Data Elements You Must Submit

All 10 elements are filed electronically through the Automated Broker Interface or the Vessel Automated Manifest System.¹ The full list:³

Seller — name and address of the entity selling the goods. If the goods aren’t being purchased (for example, an intracompany transfer), provide the owner’s name and address instead.
Buyer — name and address of the buying entity, with the same ownership alternative when there’s no sale.
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, this is the party filing the FTZ documentation.
Consignee number — the IRS number, EIN, SSN, or CBP-assigned number of the U.S. person or company 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 supplier of the finished goods from the country of export.
Ship-to party — name and address of the first party scheduled to physically receive the goods after customs release. Any of these party fields can substitute a widely recognized commercial identification number for the name and address.
Country of origin — where the goods were manufactured or produced.
Commodity HTSUS number — the Harmonized Tariff Schedule classification, at a minimum of six digits. Manufacturer, country of origin, and HTSUS number must be linked at the line-item level.
Container stuffing location — name and address of the physical location where the goods were packed into the container.
Consolidator — name and address of the party that stuffed the container or arranged the stuffing.

Before you can use an Importer of Record or consignee number, it has to be pre-registered with CBP. You can do this in person at a local port of entry or through a licensed customs broker using CBP Form 5106.⁴

The Two Carrier Elements

The carrier submits these independently of your filing:

Vessel stow plan — a diagram showing the position of every container on the vessel, required for all arriving vessels carrying containers.
Container status messages — electronic updates tracking each container’s movements and status changes from loading through arrival at the U.S. port of discharge.

When Each Element Is Due

The headline deadline is 24 hours before the cargo is loaded onto the vessel at the foreign port.⁵ But CBP treats different elements differently based on how quickly the information realistically firms up.

Four elements are fixed and must be accurate at initial filing: seller, buyer, Importer of Record number, and consignee number.⁶

Four elements are flexible: manufacturer or supplier, ship-to party, country of origin, and commodity HTSUS number. You submit your best available information up front and can update later, but every update has to be finalized no later than 24 hours before the vessel arrives at a U.S. port.² On voyages shorter than 24 hours, the deadline shifts to lading at the foreign port.

The last two importer elements, container stuffing location and consolidator, must be submitted as early as possible but no later than 24 hours before arrival in the United States.⁶ The later cutoff recognizes that stuffing details often aren’t confirmed until the goods are already at sea.

After you transmit, the system returns a confirmation with a unique transaction number. Check it right away. “Accepted” or “on file” means you’re clear. An error means correct and resubmit before the ship loads. Finding out about a rejected filing after the vessel has departed puts you in penalty territory.

Bond Required for Every Filing

Every ISF must be backed by a customs bond, and without an active bond on file CBP will reject the transmission. Most importers rely on a continuous bond covering all entries and filings for a year. If you ship infrequently, a single-transaction ISF bond (an Appendix D bond under 19 CFR Part 113) can cover an individual filing.⁷ The bond identification number goes into the ISF transmission so CBP can verify coverage.

One caveat: without a bond in place, CBP technically cannot assess liquidated damages, but it can withhold release or transfer of the cargo until it receives the required information, reviews it, and completes any needed examination.¹ Skipping the bond doesn’t save money. It trades a penalty for an indefinite hold.

Bill of Lading Matching

File the ISF at the lowest bill of lading level recorded in the vessel’s Automated Manifest System. If house bills of lading exist, the ISF goes against the house bill, not the master. CBP will not accept an ISF filed against a master bill when house bills are in use.⁴

A single ISF can cover multiple bills of lading if they go to the same importer, belong to the same shipment, and travel on the same vessel voyage.⁴

If the ISF doesn’t match the bill of lading in the manifest system, CBP treats it as late, even when the mismatch stems from a carrier change or omission after your filing was accepted. The importer still bears the burden of resolving the mismatch with the steamship line. When a liquidated damage claim arrives because of a carrier error, documented proof of that error is your best argument in a petition for relief.

Exemptions and Reduced Filings

Bulk cargo, such as grain, oil, or coal loaded directly into a vessel’s hold without containers, is fully exempt from ISF.⁸

Break bulk cargo, such as palletized goods or machinery loaded individually, is not exempt. Break bulk shipments that qualify for exemption from the 24-Hour Rule’s “prior to lading” timeline get a modified deadline: 24 hours before arrival at a U.S. port instead of 24 hours before loading at the foreign port.⁸

Cargo that stays aboard the vessel (Foreign Remaining on Board) or is immediately exported or transported for export under bond (IE and T&E shipments) requires only a reduced 5-element filing known as the ISF-5:⁵

Booking party
Foreign port of unlading
Place of delivery
Ship-to party
Commodity HTSUS number

FROB cargo must be filed prior to lading at the foreign port; IE and T&E follow the standard 24-hours-before-lading deadline.⁶ Carriers cannot bundle unrelated FROB, IE, or T&E shipments under a single ISF-5.⁴

Personal shipments like household goods are not exempt. They file as “Type 03” transactions, and the same importer identification and registration rules apply, so even an individual moving belongings needs a registered importer ID number.⁴

Penalties and Holds

Liquidated damages run $5,000 per violation, capped at $10,000 per ISF.⁵¹ The dollar figure is often the smaller problem. CBP’s other tools include:

Do-not-load holds, which instruct the carrier not to load the cargo at the foreign port.
Domestic holds, which prevent release of cargo that has already arrived.
Increased inspections, which add days of delay and examination fees for non-compliant importers.

No relief is granted when CBP determines that law enforcement goals were compromised by the violation.¹ For lesser infractions, such as a first-time late filing caused by a data entry error, CBP publishes mitigation guidelines. Importers who receive a liquidated damage claim can file a petition for relief, and documented mitigating circumstances, especially proof that a carrier caused the problem, materially improve the odds of a reduction or cancellation.

The $5,000 penalty stings, but a container sitting under a do-not-load order or a domestic hold for days or weeks can cost far more in demurrage, storage, and lost sales.⁹

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U.S. Customs and Border Protection. Importer Security Filing and Additional Carrier Requirements
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eCFR. 19 CFR Part 149 – Importer Security Filing
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eCFR. 19 CFR 149.3 – Data Elements
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U.S. Customs and Border Protection. Importer Security Filing 10+2 Program Frequently Asked Questions
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U.S. Customs and Border Protection. Import Security Filing (ISF) – When to Submit to CBP
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eCFR. 19 CFR 149.2 – Importer Security Filing Requirement, Time of Transmission
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U.S. Customs and Border Protection. CBP Form 301 – Customs Bond
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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. Importer Security Filing 10+2