Importing goods into the United States involves more than arranging transportation and preparing customs documents. For ocean shipments, one of the most important compliance requirements is the Importer Security Filing (ISF).
Commonly referred to as ISF 10+2, the Importer Security Filing provides U.S. Customs and Border Protection (CBP) with advance information about cargo traveling to the United States by vessel. CBP uses this information to identify potentially high-risk shipments before they reach U.S. ports.
For importers, understanding ISF filing requirements is essential. Filing late, submitting inaccurate information, or failing to file can lead to liquidated damages, inspections, cargo delays, and other complications.
Here is what importers should know about Importer Security Filing requirements, deadlines, and potential penalties.
What Is an Importer Security Filing?
An Importer Security Filing is an electronic submission of advance cargo information to CBP for goods arriving in the United States by ocean vessel.
The ISF rule went into effect in 2009 and applies specifically to cargo arriving by vessel. It does not generally apply to shipments entering the United States by air, truck, or rail.
The program is often called “10+2” because importers provide up to 10 data elements for U.S.-bound cargo, while ocean carriers separately provide additional information.
The purpose is security. Providing information before cargo is loaded allows CBP to evaluate shipments earlier in the transportation process.
What Are the ISF Filing Requirements?
For cargo intended to enter the United States or be delivered to a Foreign Trade Zone, the ISF generally includes 10 importer data elements.
Eight elements generally must be submitted no later than 24 hours before the cargo is loaded onto the vessel destined for the United States:
- Seller
- Buyer
- Importer of Record number or Foreign Trade Zone applicant identification number
- Consignee number
- Manufacturer or supplier
- Ship-to party
- Country of origin
- Commodity Harmonized Tariff Schedule of the United States number
Two additional pieces of information must be submitted as early as possible, but generally no later than 24 hours before the vessel arrives at a U.S. port:
- Container stuffing location
- Consolidator or stuffer
CBP also has different ISF requirements for certain transit cargo, including Foreign Cargo Remaining on Board (FROB), Immediate Exportation (IE), and Transportation and Exportation (T&E) shipments.
What Is the ISF Filing Deadline?
One of the most important ISF filing requirements is meeting the deadline.
For most U.S.-bound ocean cargo, the required information must generally be submitted at least 24 hours before the goods are loaded aboard the vessel at the foreign port.
This is an important distinction. The deadline is not based on when the vessel reaches the United States.
Waiting until cargo is already sailing toward the United States may mean the filing is already late.
Importers should therefore work with suppliers, freight forwarders, and customs brokers early enough to collect the necessary information before the vessel loading deadline.
Who Is Responsible for Filing the ISF?
The ISF Importer is responsible for ensuring the filing is submitted.
For many traditional imports, the responsible party is the owner, purchaser, consignee, or an authorized agent such as a licensed customs broker. Different rules may determine responsibility for FROB, IE, T&E, and Foreign Trade Zone shipments.
Importers commonly authorize customs brokers or other qualified agents to electronically submit ISF information on their behalf.
However, using a third party does not mean importers should ignore the process. Businesses should provide complete information as early as possible and establish procedures for communicating shipment changes.
How Is an ISF Submitted?
Importer Security Filings must be transmitted electronically through a CBP-approved system. CBP notes that ISFs can be filed through systems such as the Automated Broker Interface or Automated Commercial Environment. Importers may use a licensed customs broker or another appropriate filing provider to complete the transmission.
This is one reason establishing a relationship with an experienced customs professional can be valuable, particularly for companies that import frequently.
What Happens If Information Changes?
International shipments do not always go exactly according to plan. Suppliers, routing, destinations, and other shipment information can sometimes change after the original filing.
CBP regulations require the party that submitted the ISF to update it when information changes or when more accurate information becomes available before the goods enter the limits of a U.S. port.
Importers should therefore communicate changes promptly rather than assuming the original ISF can simply remain unchanged.
What Is the ISF Late Filing Penalty?
An ISF late filing penalty can be significant.
CBP may assess $5,000 in liquidated damages per violation for a late, inaccurate, or otherwise noncompliant ISF. CBP guidance also indicates that enforcement can include increased inspections and cargo delays.
Potential violations can involve:
- Filing the ISF late
- Providing inaccurate information
- Submitting inaccurate updates
- Failing to properly withdraw an ISF when required
CBP evaluates noncompliance based on the circumstances, and enforcement consequences can vary. The important takeaway for importers is that ISF compliance should not be treated as an administrative afterthought.
Common ISF Mistakes Importers Should Avoid
Many ISF problems can be prevented with stronger communication and planning.
One common mistake is waiting too long to request information from an overseas supplier. Since most ISF information is required before cargo is loaded, waiting until departure can create an immediate compliance problem.
Another issue is providing incomplete or inaccurate information. Incorrect manufacturer details, HTS classifications, consignee information, or bill of lading data can create filing complications.
Importers should also avoid assuming that someone else has completed the filing. Establish clear responsibilities among your supplier, freight forwarder, carrier, and customs broker.
How to Improve ISF Compliance
A few proactive steps can make the ISF process much easier.
First, collect shipment information early. Do not wait until the vessel is preparing to depart.
Second, establish a consistent process with overseas suppliers. Make sure they understand which documents and details you need and when you need them.
Third, review shipment information carefully. Confirm names, addresses, classification information, and other required details before submission.
Finally, work with an experienced customs broker who understands ISF requirements and can help identify potential problems before they affect your shipment.
Why ISF Compliance Matters
The Importer Security Filing is more than another piece of paperwork. It is part of CBP’s broader cargo security program and directly affects ocean import compliance.
Missing deadlines or providing incorrect information can create unnecessary costs and delays. For companies importing regularly, repeated problems can also disrupt supply chains and complicate relationships with customers and vendors.
A reliable ISF process helps businesses reduce compliance risks and keep shipments moving as efficiently as possible.
Krenz & Hannan International Can Help
Navigating Importer Security Filing requirements can be challenging, especially when shipments involve multiple suppliers, changing information, or tight sailing schedules.
Krenz & Hannan International can help importers understand ISF filing requirements, meet important deadlines, and navigate the broader U.S. customs clearance process.
Whether you have questions about an upcoming ocean shipment, need assistance understanding ISF requirements, or want to strengthen your import compliance procedures, the experienced team at Krenz & Hannan International is ready to help.
Contact Krenz & Hannan International today to make sure your next shipment is prepared for U.S. customs requirements before it leaves the foreign port.