How to File an ISF (10+2): Complete Step-by-Step Guide for Ocean Importers

What Is the Importer Security Filing (ISF)?

The Importer Security Filing (ISF), commonly known as 10+2, is a US Customs and Border Protection (CBP) requirement that mandates importers or their agents to electronically submit specific cargo information before goods are loaded onto vessels destined for the United States. The rule applies to all ocean shipments and was implemented in 2009 as part of the SAFE Port Act to enhance supply chain security and allow CBP to identify high-risk cargo before it reaches US shores.

The name '10+2' refers to the 10 data elements that the importer must provide, plus 2 additional data elements provided by the ocean carrier. Failure to file the ISF on time, or filing it with inaccurate information, can result in penalties of up to $5,000 per violation, cargo holds, and increased examination rates. Understanding the ISF requirements and establishing a reliable filing process is essential for any company importing goods by ocean vessel.

The 10 Importer Data Elements

1. Seller (or owner) name and address: the entity selling or owning the goods at the time of export
2. Buyer (or owner) name and address: the entity purchasing or owning the goods being shipped to the US
3. Importer of record number: the IRS number, EIN, or CBP-assigned number of the entity responsible for customs entry
4. Consignee number: the IRS number, EIN, or CBP-assigned number of the entity receiving the goods
5. Manufacturer (or supplier) name and address: the entity that manufactured, produced, or grew the goods
6. Ship-to party name and address: the physical location where the goods will be delivered
7. Country of origin: the country where the goods were manufactured or produced (6-digit HTS code level)
8. Commodity HTS number: the 6-digit HTS code for each commodity being imported
9. Container stuffing location: the physical address where the goods were loaded into the container
10. Consolidator (stuffer) name and address: the entity that stuffed or loaded the container

Filing Deadlines and Timing

The ISF must be filed no later than 24 hours before the cargo is loaded onto a vessel at the foreign port of departure. This is a hard deadline, and late filings will trigger penalties regardless of whether the goods ultimately clear customs without issues. For certain data elements where the information is not yet known at the time of initial filing, CBP allows the use of flexible ISF filings. Under this approach, you file the ISF with the best available information by the deadline and then update the filing with accurate data as it becomes available, but no later than 24 hours before the vessel arrives at the first US port.

Step-by-Step Filing Process

Step 1: Gather Required Information

Begin by collecting all 10 data elements from your supply chain partners. The seller and manufacturer information should come from your purchase order and commercial invoice. The container stuffing location and consolidator information should come from your freight forwarder or the overseas consolidator. Your importer of record number and consignee number should be established before your first shipment. The HTS code should be determined through proper classification of each commodity in the shipment.

Step 2: Engage Your Filing Agent

Most importers use a licensed customs broker or a third-party filing service to submit their ISF. While you can file the ISF yourself using the ACE (Automated Commercial Environment) system, the process requires an ACE portal account and familiarity with the filing interface. Your customs broker can file the ISF on your behalf, but you remain responsible for the accuracy and timeliness of the filing. Ensure your broker has a clear process for receiving ISF data from you and confirm their filing timeline to avoid last-minute scrambles.

Step 3: Submit and Monitor

Once the ISF is submitted through ACE, CBP will issue a confirmation with a transaction number. Monitor the filing status to ensure it is accepted without errors. If CBP rejects the filing due to data issues, you must correct and resubmit before the deadline. After the initial filing, update any flexible data elements as the information becomes available. Track the vessel departure and arrival dates to ensure all updates are submitted within the required timeframes.

Common ISF Filing Mistakes

• Filing late: submitting after the 24-hour pre-loading deadline is the most common violation
• Incorrect manufacturer: using the trading company instead of the actual factory or production facility
• Wrong HTS code: using a 4-digit heading instead of the required 6-digit subheading
• Misidentifying the seller: confusing the seller (who owns the goods) with the manufacturer
• Missing container stuffing location: failing to provide the actual address where goods were loaded
• Not updating flexible filings: filing with placeholder data but never submitting the updates
• Using the wrong importer of record number: especially common when the IOR changes between booking and entry

ISF Penalties and Enforcement

CBP has progressively increased ISF enforcement since the rule went into effect. Penalties for late filing, inaccurate filing, or failure to file can reach $5,000 per violation. In practice, first-time violators with otherwise clean records may receive lower penalties or warning letters, but repeat offenders face the full penalty amount. CBP can also place holds on cargo associated with ISF violations, preventing release until the filing issues are resolved. These holds can result in significant demurrage and detention charges that far exceed the penalty itself. Maintaining a compliant ISF filing process is one of the most straightforward ways to avoid unnecessary costs and delays at the port.