The Importer Security Filing (ISF, usually called "10+2") is an electronic filing that gives US Customs and Border Protection (CBP) ten items of shipment data about ocean cargo before it is loaded on a vessel bound for the United States. The "+2" refers to two extra data sets that the carrier must send (a vessel stow plan and container status messages). The core rule: for a normal import, the ISF must reach CBP no later than 24 hours before the cargo is loaded at the foreign port, it is filed by or for the party causing the goods to arrive, and it is a security and targeting filing, separate from the carrier's manifest and from the customs entry that pays duty. It applies to ocean freight only, including LCL, and it is backed by a bond and by $5,000 liquidated damages per violation.
This guide is the practical companion to our explainers on US customs bonds and how customs clearance works step by step. It covers who files, the data elements, timing, exceptions, penalties, and the workflow a forwarder or broker follows. Everything below is checked against 19 CFR Part 149, CBP's ISF FAQ (May 2023 edition) and CBP's ISF mitigation guidelines. Check the current rule before relying on any detail.
What the ISF is, and what it is not
CBP introduced ISF under the SAFE Port Act of 2006 and an interim final rule published in the Federal Register on 25 November 2008 (73 FR 71730). The requirement took effect on 26 January 2009, and CBP's FAQ gives 26 January 2010 as the date full enforcement began. The purpose is risk targeting: CBP wants information about who is buying, who made the goods, where they were packed and what they are, early enough to decide whether to examine a container before it is loaded or at least before it is unloaded in the United States.
Three common misconceptions are worth correcting early.
- It is not the manifest. The carrier (or an NVOCC) files the cargo declaration, which CBP must receive 24 hours before the cargo is laden at the foreign port (19 CFR 4.7(b)(2)). The ISF is a second, separate filing about the same cargo. CBP's FAQ states that ISF information is not part of the carrier manifest.
- It is not the entry. The ISF is filed before departure and does not declare value or duty. The customs entry is made later, within 15 calendar days after the goods land (19 CFR 141.5). An ISF can be combined with an entry in one transmission (a "unified entry"), but that is optional and runs through CBP's ABI filing channel.
- It is not only for containers or full loads. CBP's FAQ says an ISF is required for all non-bulk cargo regardless of shipment size, so LCL pallets and cartons need one, filed at house bill level.
Who files an ISF
19 CFR 149.1 defines the "ISF Importer" as the party causing goods to arrive within the limits of a US port by vessel. For ordinary imports that is the goods' owner, purchaser, consignee, or an agent such as a licensed customs broker. The ISF Importer is the party liable for timeliness and accuracy, even when an agent transmits the data. For foreign cargo remaining on board (FROB), the ISF Importer is the carrier or the NVOCC (CBP's FAQ says a May 2018 final rule extended the FROB definition to NVOCCs). For immediate exportation (IE), transportation and exportation (T&E) and foreign trade zone (FTZ) cargo, the owner, purchaser, consignee or agent files, and may be the same party that files the IE, T&E or FTZ paperwork.
In practice a US importer usually hires a customs broker or a forwarder with a US filing capability, and gives that agent a power of attorney. Under 19 CFR 149.5, authorized agents must hold the power of attorney in English, and keep it until revoked and for five years after revocation. If the importer does not have a bond, the agent filing on its behalf may use the agent's own bond, which means the agent's bond is the one CBP charges if the filing breaches the rules. That is why many agents will not file for a new importer without collateral or a single-transaction bond arranged first. Our guide to whether you need a customs broker explains the wider relationship.
Two points for forwarders and NVOCCs. First, the ISF must be filed at the lowest bill of lading level that will be recorded in CBP's system: a house bill or a simple (straight) bill. CBP does not accept an ISF against a master bill of lading. Second, an NVOCC that issues a house bill on FROB cargo is itself the ISF Importer for that shipment. See NVOCC versus freight forwarder and bill of lading types for why the bill level matters.
The 10 importer data elements
For a standard shipment, 19 CFR 149.3(a) requires ten elements, with the manufacturer, country of origin and tariff number linked at line-item level.
| # | Element | Practical note |
|---|---|---|
| 1 | Seller (owner) | Name and address of the party selling the goods. |
| 2 | Buyer (owner) | The party that purchased the goods. This can change if goods are sold in transit, which triggers an update. |
| 3 | Importer of record number (or FTZ applicant ID) | An IRS (EIN) number, a Social Security number, or a CBP-assigned number from CBP Form 5106. |
| 4 | Consignee number(s) | Same number types as the importer of record number. |
| 5 | Manufacturer (or supplier) | Name and address of the party that makes or supplies the goods, linked to the commodity line. |
| 6 | Ship-to party | The party or location the goods are first delivered to in the United States after release. |
| 7 | Country of origin | Determined under US customs law, not simply the country of export. |
| 8 | Commodity HTS number | At least six digits (HTS-6); up to ten digits is accepted. CBP's FAQ says a discrepancy at the six-digit header level found at inspection can make an ISF inaccurate. See how to find the right HS code. |
| 9 | Container stuffing location | Where the goods were loaded into the container. |
| 10 | Consolidator (stuffer) | The party that stuffed or consolidated the container. |
Elements 9 and 10 matter most to forwarders because they are often known only after the cargo is packed. The other eight must be filed 24 hours before loading.
The 2 carrier elements
The "+2" are carrier filings under 19 CFR 4.7c and 4.7d, not part of the ISF itself. The importer never files them and CBP's FAQ says the importer has no access to the carrier's data.
- Vessel stow plan: CBP must receive it no later than 48 hours after the vessel leaves the last foreign port, or before arrival at the first US port for voyages under 48 hours. Vessels carrying only bulk or break bulk cargo are exempt.
- Container status messages (CSMs): reports of container events such as booking confirmation, gate movements, loading and discharge. Carriers send each message within 24 hours of entering it in their own equipment-tracking system, and need only report messages they already create.
The deadline: 24 hours before loading
Under 19 CFR 149.2, the importer's data (seller, buyer, importer of record number, consignee, manufacturer, ship-to party, country of origin and HTS number) must be filed no later than 24 hours before the cargo is laden aboard the vessel at the foreign port. CBP's FAQ says an ISF filed less than 24 hours before lading is late, and in practice CBP measures timeliness from the vessel departure time minus 24 hours. The deadline is the same for a 2-day voyage from Mexico as for a 5-week voyage from Asia. The FAQ says each port decides how to enforce on short voyages, but the filing time itself does not change.
Container stuffing location and consolidator have a later outer limit: they are due as early as possible and no later than 24 hours before arrival at the first US port. CBP also allows flexible filing for some situations. If the importer does not yet know the exact country of origin or HTS number, it can file a range of possibilities (action code FR); if the stuffing location or consolidator is unknown, it can file under flexible timing (FT); or both (FX). Every flexible filing must be updated to the final data (action code CT) as soon as it is known, and no later than 24 hours before the vessel arrives at the first US port.
Updates, bill of lading matching and "inaccurate" filings
Filing on time is only half of compliance. 19 CFR 149.2 requires the ISF Importer to update the filing if information changes, or more accurate information becomes available, before the goods arrive. Under the FAQ:
- The ISF must match a bill of lading on file in CBP's system at least 24 hours before arrival at the first US port. An ISF that does not match by then is treated as inaccurate. Correcting the bill number after the vessel has arrived is too late.
- If goods are sold while on the water, update the buyer and any other changed field rather than deleting and re-filing, because deleting and re-filing during the voyage exposes the importer to a late-filing claim.
- If a bill of lading is split or diverted into new bills on the same vessel, update the original ISF with the new bills. A split across two vessels needs a separate ISF.
- If the goods will not come to the United States after all, the ISF should be withdrawn. Failing to withdraw is itself a violation.
- CBP's FAQ says there is no limit on the number of deletions and that CBP does not view them negatively, since failing to delete a filing that should go can cost a claim.
Where the filer got data from another party and could not reasonably verify it, CBP's guidelines say the filer may file on the basis of what it reasonably believes to be true. That is not a licence to guess. It is a reason to document where each field came from.
Which shipments need an ISF, and which do not
| Shipment | ISF position (from CBP's FAQ and 19 CFR Part 149) |
|---|---|
| Ocean cargo to the United States (FCL or LCL) | ISF-10 required, filed at house or simple bill level. |
| Air, truck and rail imports | No ISF. It applies only to goods scheduled to arrive by vessel. |
| Cargo going by sea to Canada or Mexico, then into the US by truck or rail | No ISF if the vessel never calls at a US port. If the vessel calls at a US port first, the cargo counts as FROB and an ISF-5 is required. |
| Bulk cargo (loose, homogeneous cargo such as grain or oil) | Exempt. Once cargo is placed in a container it is no longer bulk and needs an ISF. |
| Break bulk exempt from the 24-hour manifest rule | ISF still required, but due 24 hours before arrival in the US instead of before loading. |
| FROB, IE and T&E cargo (and goods for an FTZ) | ISF-5 with five elements: booking party, foreign port of unlading, place of delivery, ship-to party and HTS-6. FROB is filed by the carrier or NVOCC. CBP's FAQ says most importers choose an ISF-10 for FTZ goods. |
| Empty containers, ship's spares and ship's equipment | No ISF. Empty containers are still reported through stow plans and CSMs. |
| Informal entries, household goods, military, diplomatic, carnet and mail shipments | ISF required, using special transaction types. Several of these types are not enforced for the bond requirement. |
Note that "ocean" includes an ocean leg of a multimodal move. If cargo arrives in the US by vessel, even as part of a longer through-booking, ask whether an ISF applies. Note too that imports into Puerto Rico from non-US locations are covered, because Puerto Rico is within the US customs territory.
Low-value shipments are a frequent source of confusion. CBP's FAQ says informal shipments need an ISF (transaction type 11) and also lists a de minimis / Section 321 / Entry Type 86 transaction type. De minimis treatment has been changing, so check current rules in our guide to Section 321 and Type 86 entries before assuming a low-value ocean parcel needs no filing.
Bonds: what secures the ISF
An ISF must be secured by a bond. CBP's FAQ says the ISF can be covered by a continuous importation bond (activity codes 1, 2, 3 or 4), a stand-alone ISF bond (activity code 16, with its own form in Appendix D to 19 CFR Part 113), or a single-transaction bond. The ISF bond amount does not depend on the value of the cargo: the FAQ gives face amounts of $10,000 for a single-transaction ISF bond and $50,000 for the minimum continuous bond. If the importer files a unified entry, one bond must secure both the entry and the ISF, and a single-transaction bond must be increased by $10,000 to cover the ISF part.
As a matter of policy CBP does not enforce the bond requirement for household goods and personal effects, government and military, diplomatic, carnet, international mail and informal shipment transaction types, though CBP can still claim against an existing bond. Bond mechanics, activity codes and sizing are covered in our US customs bonds guide, which this post does not repeat.
Penalties, holds and what actually happens
The default remedy is liquidated damages under the bond. Under 19 CFR 113.62(j) (and the matching clauses in 113.63, 113.64, 113.73 and the ISF bond) the principal and surety agree to pay $5,000 for each violation. CBP's mitigation guidelines (CBP Dec. 09-26, published 17 July 2009) say a claim may be assessed for:
- a late ISF: $5,000;
- an inaccurate ISF: $5,000;
- the first inaccurate ISF update: $5,000;
- failing to withdraw an ISF when required: $5,000.
Liquidated damages cannot be assessed for failure to file if no bond is in place, but CBP can withhold release of the cargo until an ISF is provided and reviewed, limit the permit to unlade, and pursue other penalties under 19 USC 1595a(b) for serious or repetitive violations. Per the guidelines, for a first late or inaccurate claim the amount may be cancelled on payment of $1,000 to $2,000 if CBP finds law enforcement goals were not compromised, and $2,500 or more for later claims. Claims can be cancelled in full where CBP issued them in error or through no fault of the ISF Importer (the FAQ's example is a bill of lading mismatch caused by a CBP system problem). CBP will also weigh aggravating factors such as evidence of smuggling or a rising error rate. ISF liability does not expire quickly: the FAQ cites a six-year limitations period.
The cargo consequences are often costlier than the claim. CBP can place a hold on cargo that arrives without an ISF, which must be lifted manually by each port, followed by an examination. For consolidations, CBP's FAQ says any port can hold a LCL container if a single house bill has no ISF, and the CFS can still unload and process the house bills that do have one. One shipper's missed filing can therefore delay everyone's cargo in that container. A "do not load" message is different: the FAQ says CBP reserves those for national security threats, and ISF is only one factor. So the common outcome of a missed ISF is a destination hold and exam, plus a claim, not a refusal to load.
What changed in 2025 and 2026
As of 6 October 2026 I found no change to the ISF data elements, the 24-hour deadline or the $5,000 figure. The eCFR's amendment metadata for Part 149 shows nothing after 2021, CBP's own ISF page was last updated in July 2023, and the ISF FAQ is still the May 2023 edition. Some industry write-ups say CBP has been collecting ISF penalties more systematically since 2025; I could not find that stated on a CBP page, so treat it as unconfirmed.
The nearby changes are about bonds and importer identity, and they touch ISF filers in practice:
- Electronic bonds (proposed). A CBP proposed rule published on 13 February 2026 would require most bonds to be transmitted to CBP electronically by the surety, with comments closed on 14 April 2026. It would amend 19 CFR 149.5(b) so that the ISF bond must have been transmitted to CBP, and keeps the rule that an agent filing for an importer without a bond may use the agent's bond. I could not confirm a final rule.
- Executive Order 14411 (3 June 2026). "Strengthening Customs Enforcement" directs tougher bond, asset and good-standing requirements for importers of record and a 50 percent penalty floor. The sections I read do not mention the ISF, and most provisions need further rulemaking.
- Importer of record numbers (effective 18 September 2026). A CBP notice in the Federal Register on 19 August 2026 says CBP will immediately void an importer of record number if the CBP Form 5106 data is inaccurate or incomplete. The notice does not mention the ISF, but the importer of record number is an ISF data element, so a voided number is a problem for any pending filing. See what to check on a Form 5106.
A practical forwarder and broker workflow
- At booking: confirm the shipment is going by vessel to a US port and who the ISF Importer is. The Incoterm tells you who arranges the move but does not by itself decide who is the ISF Importer. See Incoterms 2020.
- Collect the data from the supplier: seller, manufacturer name and address, ship-to party, country of origin, a defensible HTS-6, stuffing location and consolidator. Ask for the invoice and packing list at the same time.
- Get authority and a bond: a power of attorney from the importer, plus a bond that is active on the day the ISF is created.
- File before the 24-hour deadline, not at it: measure from the vessel's scheduled departure, and allow for the vessel leaving early. Use flexible filing only when the data really is unknown.
- Match the bill: once the house bill number exists, make sure the ISF carries it, and watch for the CBP message showing the bill is on file. For consolidations see FCL versus LCL.
- Update and withdraw: amend for sales in transit, bill splits and changed data until arrival, and withdraw if the cargo is not coming.
- Keep the evidence: where each field came from, when it was filed and when it was updated. It is what supports a petition to mitigate.
What to do next
- Check whether any of your US-bound shipments travel by vessel, including the ocean leg of a multimodal booking.
- Name the ISF Importer on each shipment and put a power of attorney and an active bond in place before booking.
- Add the ISF data fields to your supplier booking form so they arrive before cargo cut-off.
- Check that the importer of record number and Form 5106 details are accurate.
If you are a shipper looking for a forwarder or broker that handles US imports, more than 29,300 logistics companies are searchable by country and service in the CargoLinked directory, and the public requests board lists freight that shippers have posted for forwarders to quote on directly.
This article is general information, not legal, customs or tax advice. ISF rules, bond requirements and penalty guidelines change, and individual ports apply them differently. Confirm the current requirements with US Customs and Border Protection or a licensed customs broker before filing.
