Importer Security Filing

Importer Security Filing

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Importer Security Filing (ISF) and Additional Carrier Requirements

The Importer Security Filing, commonly known as the “10+2” initiative, is a Customs and Border Protection (CBP) regulation that requires importers and vessel operating carriers to provide additional advance trade data to CBP for non-bulk cargo shipments arriving into the United States by vessel.  Under the ISF rule, the “Importer Security Filing (ISF) Importer,” or their agent (e.g., licensed customs broker), must electronically submit certain advance cargo information to U.S. Customs and Border Protection (CBP) in the form of an Importer Security Filing. This requirement only applies to cargo arriving in the United States by ocean vessel; it does not apply to cargo arriving by other modes of transportation.  Failure to comply with the ISF rule could ultimately result in monetary penalties, increased inspections, and delay of cargo.

Who is responsible for the ISF filing?

The ISF Importer is required to submit the Importer Security Filing. The ISF Importer is defined as the party causing the goods to arrive within the limits of a port in the United States by vessel. Typically, the ISF Importer is the goods’ owner, purchaser, consignee, or agent such as a licensed customs broker.

However, for foreign cargo remaining on board (FROB), the ISF Importer is the carrier or the Non-Vessel Operating Common Carrier (NVOCC). For immediate exportation (IE) and transportation and exportation (T&E) in-bond shipments, and goods to be delivered to a foreign trade zone (FTZ), the ISF Importer is the party filing the IE, T&E, or FTZ documentation, including the goods’ owner, purchaser, consignee, or agent such as a licensed customs broker.

An importer may designate an agent to file the ISF on its behalf and that agent does not have to be a licensed customs broker, nor does it have to be located within the United States. The regulations do, however, require the agent to retain powers of attorney in English until revoked and require the agent to provide proof of powers of attorney and revocation upon request by CBP.

What data elements must be provided?

For shipments consisting of goods intended to be entered into the United States and goods intended to be delivered to a Foreign Trade Zone, ISF Importers, or their agent, must provide ten data elements and two Additional Carrier Requirements , commonly known as ISF-10 or “10+2”.

For shipments consisting entirely of FROB and shipments consisting entirely of goods intended to be transported in-bond as an IE or T&E, the Importer Security Filing must consist of five elements (known as ISF-5).

In-Depth Coverage: Country of Origin

ISF 10 Data Elements

U.S. bound Cargo (Includes FTZ and IT) requires the electronic filing of an Importer Security Filing (ISF) comprised of 10 data elements. ISF Importers, or their agent, must provide eight data elements, no later than 24 hours before the cargo is laden aboard a vessel destined to the United States. 

Those data elements include:

1. Importer of Record Number

Internal Revenue Service (IRS) number, Employer Identification Number (EIN), Social Security Number (SSN), or CBP assigned number of the entity liable for payment of all duties and responsible for meeting all statutory and regulatory requirements incurred as a result of importation.  For goods intended to be delivered to an FTZ, the IRS number, EIN, SSN, or CBP assigned number of the party filing the FTZ documentation with CBP must be provided.

2. Consignee Number

Internal Revenue Service (IRS) number, Employer Identification Number (EIN), Social Security Number (SSN), or CBP assigned number of the individual(s) or firm(s) in the United States on whose account the merchandise is shipped. This element is the same as the “consignee number” on CBP Form 3461.

3. Seller (Owner)

Name and address of the last known entity by whom the goods are sold or agreed to be sold. If the goods are to be imported otherwise than in pursuance of a purchase, the name and address of the owner of the goods must be provided.

4. Buyer (Owner)

Name and address of the last known entity to whom the goods are sold or agreed to be sold. If the goods are to be imported otherwise than in pursuance of a purchase, the name and address of the owner of the goods must be provided.

5. Ship to Party

Name and address of the first deliver-to party scheduled to physically receive the goods after the goods have been released from customs custody.

In-Depth Coverage: Marketing and Advertising Compliance

6. Manufacturer or Supplier

Name and address of the entity that last manufactures, assembles, produces or grows the commodity or name and address of the supplier of the finished goods in the country from which the goods are leaving.

7. Country of Origin

Country of manufacture, production, or growth of the article, based upon the import laws, rules, and regulations of the United States. This element is the same as the “country of origin” on CBP Form 3461.

8. Commodity HTS-6 Number

The HTSUS number must be provided to the six-digit level. Alternatively, the filer may choose to provide the HTSUS number to the 10-digit level.

Two additional data elements must be submitted as early as possible, no later than 24 hours prior to the ship's arrival at a U.S. port. These data elements are:

9. Container Stuffing Location

Name and address(es) of the physical location(s) where the goods were stuffed into the container. For break bulk shipments, the name and address(es) of the physical location(s) where the goods were made “ship ready” must be provided.  The “scheduled” stuffing location may be provided. This may be the same name/address as the manufacturer (supplier). If a “factory load”, simply provide the name and address of the factory.

10. Consolidator (Stuffer) Name/Address

Name and address of the party who stuffed the container or arranged for the stuffing of the container must be provided. For break bulk shipments, the name and address of the party who made the goods “ship ready” or the party who arranged for the goods to be made “ship ready” must be provided.  If no consolidator is used, e.g., “factory load” shipments, provide the name/address of the manufacturer (supplier).

In-Depth Coverage: Importing Food Products 

Additional Carrier Requirements

In addition to the existing carrier requirements pursuant to the 24-Hour Rule, the rule requires carriers to submit a vessel stow plan and container status messages for certain scenarios pertaining to cargo containers destined to the United States.

Vessel Stow Plan: Carriers must transmit the stow plan, via the Automated Manifest system (AMS), secure file transfer protocol or email, so that it is received by CBP no later than 48 hours after the carrier's departure from the last foreign port. For voyages less than 48 hours, CBP must receive the information prior to the vessel's arrival at the first port in the U.S.  The stow plan must include the vessel name, vessel operator and voyage number. With regard to each container, the vessel stow plan must also include the container operator and the equipment number, equipment size and type, stow position, hazmat code, port of lading and port of discharge.

Container Status Messages (CSM): CSMs must be submitted to CBP daily for certain events relating to all containers laden with cargo destined for the U.S. by vessel. Carriers must submit a CSM when any of the required events occurs if the carrier creates or collects a CSM in its tracking system reporting that event.

Coded Transactions

CBP has programmed its system to accept 11 different ISF-10 Transaction types. More types may be added as needed.

Transaction type 01: Standard

This transaction type covers the vast majority of commercial shipments.

Transaction type 02: Ship-To/To Order

This transaction type should be used for shipments that have not yet been sold to a buyer in the U.S. This is typically used for commodities shipments (e.g., coffee beans, cocoa, etc.).

Transaction type 03: HHG/PE

This transaction type should be used for all household goods (HHG) and personal effects (PE) shipments. This includes shipments for returning military members, other U.S. government personnel and their families. No bond is required.

In-Depth Coverage: Importing Cosmetics

Transaction type 04: Gov’t & Military

This transaction type should be only used for actual government or military shipments and not the personal effects or household goods of individual government personnel. No bond is required.

Transaction type 05: Diplomatic

This transaction type should be used only by foreign entities entitled to diplomatic immunity. Returning U.S. diplomatic personnel are not entitled to use this transaction type. No bond is required.

Transaction type 06: Carnet

This transaction type covers shipments arriving under a carnet. No bond is required.

Transaction type 07: U.S. Goods

This transaction type is reserved for shipments containing solely U.S. Goods Returned.

Transaction type 08: FTZ Shipments

This transaction type is reserved for shipments going into a Foreign Trade Zone.

Transaction type 09: International Mail

This transaction type is reserved for USPS mail shipments. No bond is required.

Transaction type 10: OCS Shipments

This transaction type is reserved for shipments arriving from a U.S. outer continental shelf point or from vessels operating over a U.S. OCS point (e.g. rigs, derrick barges, seismic vessels).

Transaction type 11: Informal

This transaction type is reserved primarily for low-value shipments where formal entry is not required. No bond is required.

        Sub Codes:

        1.   Section 321 (goods up to $800)

        2.   Informal (goods under $2,500)

        3.   03 General Note 3(e) (goods not subject to the provisions of the tariff schedule)

In-Depth Coverage: USDA-Regulated Products

ISF 5 Data Elements + Additional Carrier Requirement for Transit Cargo

For shipments consisting entirely of FROB and shipments consisting entirely of goods intended to be transported as Immediate Exportation (IE) or Transportation and Exportation (T&E) in-bond shipments, ISF Importers, or their agents, must submit the following five data elements to CBP.

1. Booking Party Name/Address

Name and address of the party who initiates the reservation of the cargo space for the shipment.  A widely recognized commercially accepted identification number for this party may be provided in lieu of the name and address. CBP will accept a DUNS number in lieu of the name and address.

2. Ship To Party

Name and address of the first deliver-to party scheduled to physically receive the goods after the goods have been released from customs custody.  CBP is looking for the actual deliver to name/address; not the corporate address.  If unknown, provide the name of the facility where the goods will be unladen. 

3. Commodity HTS-6 Number

The HTSUS number must be provided to the six-digit level.  The HTSUS number may be provided to the 10-digit level.

4. Foreign Port of Unlading

Port code for the foreign port of unlading at the intended final destination must be provided.  Note: This may be the inland foreign port code for TE in-bond movements. CBP will accept UN LOC Codes and the Bureau of Census “Schedule K” codes. 

5. Place of Delivery

City code for the place of delivery must be provided.  It is the foreign location where the carrier’s responsibility for the transport of the goods terminates.  UN LOC codes and Bureau of Census “Schedule K” codes are acceptable.

In-Depth Coverage: Importing Medical Device 

Exemption from Importer Security Filing

Bulk cargo

An Importer Security Filing is not required for bulk cargo.  Bulk cargo is defined as homogeneous cargo that is stowed loose in the hold and is not enclosed in any container such as a box, bale, bag, cask, or the like. Such cargo is also described as bulk freight. Specifically, bulk cargo is composed of either:

(1) Free flowing articles such as oil, grain, coal, ore, and the like, which can be pumped or run through a chute or handled by dumping; or

(2) Articles that require mechanical handling such as bricks, pig iron, lumber, steel beams, and the like.

Exemption from 24-Hour Rule: Break Bulk cargo

For break bulk cargo that is exempt from the 24 hour prior to lading timing requirement for 24 Hour Rule purposes, the Importer Security Filing is required 24 hours prior to arrival. Break bulk cargo is defined as cargo that is not containerized, but which is otherwise packaged or bundled.

How will the rule be enforced?

CBP may issue liquidated damages of $5,000 per violation for the submission of an inaccurate, incomplete or untimely filing. If goods for which an ISF has not been filed arrive in the U.S., CBP may withhold the release or transfer of the cargo; CBP may refuse to grant a permit to unlade for the merchandise; and if such cargo is unladen without permission, it may be subject to seizure. Additionally, noncompliant cargo could be subject to “do not load” orders at origin or further inspection on arrival.

In-Depth Coverage: Customs Valuation

ISF Bond Requirement

The ISF Importer or his/her agent may obtain a continuous bond (type 1, 2, 3, or 4) or an Appendix D ISF stand-alone ISF bond (single-transaction or continuous).

The bond amount for the Appendix D (19 CFR Appendix D to Part 113 – Importer Security Filing Bond) stand-alone ISF bonds will be $10,000 for single transaction and $50,000 for continuous transaction. The amount of the ISF bond is not based on the value of the cargo.

Appendix D stand-alone continuous ISF bonds must be submitted to and approved by CBP’s Office of Administration in advance of the filing of an ISF. Once approved, CBP will record the bond information and issue a unique bond identification number. Upon the filing of an ISF, the ISF Importer or his/her agent must denote the usage of the Appendix D stand-alone continuous ISF bond on the ISF by identifying either bond activity code 16 or bond type 8 (continuous) and the importer ID number against which the bond was recorded.

 If an agent is submitting an ISF on behalf of another party and the agent posts his own bond, the agent agrees to have his bond charged if there are breaches of obligations regarding the filing.

CBP will accept one bond for the ISF filing and a separate bond for entry. However, if the ISF Importer and the Importer of Record are the same party and the ISF and entry are submitted to CBP via the same electronic transmission (unified filing of entry and ISF), that party must submit one bond that secures both the ISF and the entry. If a unified entry and ISF filing is sent, the bond obligated on the entry cover both the entry and the ISF for both continuous and single transaction bonds.

Certain types of ISF coded transactions will not require a bond to cover the ISF filing requirements. The bond requirements have been waived for the following ISF coded transactions:

Type 3- Household Goods/Personal Effects

Type 4- Government and Military

Type 5- Diplomatic

Type 6- Carnets

Type 9- International Mail

Type 11- Informal Shipments

ISF Submission Type Changes

In some instances, it becomes necessary to change the ISF type from an ISF-5 to an ISF-10 or reversely. For example, a shipment that was going to be immediately exported (IE) to Canada upon arrival into the U.S. is actually sold to a U.S. party instead. The new party would like to enter the goods into the U.S.

In addition to the two basic submission types (ISF10 submission and ISF-5 submission), there are the following four submission types.

ISF submission type 3: ISF-5 submission type is being changed to an ISF-10

CBP has created a process whereby a new ISF-10 may be filed to replace an existing ISF-5. In these instances, a new ISF-10 must be created and ISF Submission Type 3 must be selected to denote that an ISF-10 will replace the existing ISF-5. An active ISF-5 filing must already exist for this shipment against the same bill of lading number (i.e., lowest ACE bill of lading number) in order for this new filing to be valid.

In the scenario described above, the new party who would like to enter the goods into the U.S. instead of immediate exportation to Canada needs to change the ISF-5 to an ISF-10.

In terms of the business process, CBP expects the new ISF-10 to be completed electronically prior to seeking the written permission from the local CBP port director. Accordingly, the ISF-10 transaction number needs to be referenced in the written letter to the local port director as part of the request for the change from a shipment type requiring an ISF-5 to a shipment type requiring an ISF-10.

ISF submission type 4: ISF-10 submission type is being changed to an ISF-5

An ISF-10 filing can be replaced by an ISF-5 filing. In this case, ISF Submission Type 4 will be used to show that an ISF-10 is being changed to an ISF-5. As a matter of policy, there is no requirement to obtain port director approval for these types of changes.

The new ISF-10 may be submitted by the original ISF Importer (or her agent), or by another party who would then be liable for the ISF-10. This submission type change allows a new ISF to be filed after the goods have departed a foreign port and prior to entry release of the goods in the United States.

ISF submission type 5: Late ISF-10

ISF submission type 6: Late ISF-5

The ISF is required at least 24 hours prior to the vessel departure. If the ISF is completed the same day the vessel sails, it will be considered a violation and it can be expected that CBP will issue a claim for an untimely filing. CBP uses the vessel departure date minus 24 hours to measure timeliness.

Importers who are unable to secure a bond after the ISF filing deadline may elect to use the ISF Submission Type 5 (Late ISF-10, No Bond) or ISF Submission Type 6 (Late ISF-5, No Bond). These submission types are subject to change. The use of these ISF submission types is an acknowledgment that the ISF requirements were not met and that the ISF is late. CBP reserves the right to take any and all appropriate actions (e.g., cargo holds and examinations) to enforce the ISF requirements in these cases.

Please note that ISF Importers who already have coverage under existing Type 1, 2, 3, or 4 continuous bonds are not to use these submission types. In addition, CBP monitors the usage of these new ISF submission types and pays particular attention to any entity that attempts to use these submissions more than once.

Liquidated damages for the different late-filing scenarios

ISF bond obligations commence 24 hours prior to vessel departure. The ISF Importer is liable for up to $10,000 per ISF for any of the following reasons:

  • Late ISF: $5,000 per late filing, or untimely filing of the ISF update, and/or untimely update to a flexible ISF
  • Inaccurate or Incomplete ISF: $5,000 per inaccurate or incomplete filing, which includes failure to update a flexible ISF at least 24 hours prior to vessel arrival, and/or arriving without securing a match to the bill of lading

1.  If importing from Virgin Island, American Samoa or Guam, you MUST file ISF

2.  If you are importing from Puerto Rico to U.S. or if you are exporting from U.S. to Puerto Rico (NO ISF is need it)

3.  If your goods arrived into Canada by vessel and if trucking or railing into U.S. (as long as shipment are associated with bill of lading at AMS) (MUST file ISF)

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