ISF 10+2 Filing: Requirements, Timelines, and Penalties for US Importers

What Is the Importer Security Filing (ISF)?

The Importer Security Filing (ISF), commonly known as "10+2" filing, is a mandatory advance cargo information requirement enforced by CBP under 19 CFR Part 149. Implemented in 2009 as part of the SAFE Port Act, the ISF requires importers (or their agents) to electronically submit 10 data elements about incoming ocean cargo to CBP at least 24 hours before the cargo is loaded onto a vessel at the foreign port of origin. The ocean carrier must separately provide 2 additional data elements (the vessel stow plan and container status messages), which is why the program is called "10+2."

The purpose of the ISF is national security: CBP uses the advance information to assess risk and target high-risk containers for inspection before they arrive at US ports. But for importers, the ISF has significant compliance implications — it is one of the most frequently penalized import requirements, and violations can result in monetary penalties, cargo holds, and increased scrutiny on future shipments.

The 10 Data Elements Importers Must Provide

1. Seller (owner) name and address: The entity that last sold the goods before they were exported to the US.
2. Buyer (owner) name and address: The entity that purchased the goods for import into the US.
3. Importer of Record number: The IRS number, EIN, or CBP-assigned number of the US importer of record.
4. Consignee number: The IRS number, EIN, or CBP number of the party to whom the goods are being shipped in the US.
5. Manufacturer (or supplier) name and address: The entity that manufactured, produced, or grew the goods.
6. Ship-to party name and address: The first deliver-to address for the goods in the US after release from CBP.
7. Country of origin: The country where the goods were manufactured, produced, or grown (6-digit HTSUS level).
8. Commodity HTSUS number: The 6-digit (minimum) Harmonized Tariff Schedule classification code for the goods.
9. Container stuffing location: The name and address of the physical location where the goods were loaded into the container.
10. Consolidator (stuffer) name and address: The entity that loaded the goods into the container.

ISF Filing Deadlines

The ISF must be filed no later than 24 hours before the cargo is loaded onto the vessel at the foreign port of origin — not 24 hours before arrival in the US. This is a critical distinction. For containerized cargo, this means the ISF must be transmitted to CBP via ABI/ACE before the container is loaded onto the ship. For FROB (Foreign Remaining On Board) cargo and cargo to be exported via a foreign port (IE cargo), modified deadlines may apply.

ISF amendments are permitted. If certain data elements are not available at the time of initial filing (such as the exact ship-to address), CBP allows updates up to 24 hours before vessel arrival in the US. However, the initial filing with all known information must still be made before vessel loading. Late ISF filings — those transmitted after the cargo has been loaded — are subject to penalties regardless of whether the data is accurate.

Penalty Structure for ISF Violations

• Late filing: $5,000 per violation for failing to file the ISF before the 24-hour deadline. Each bill of lading is a separate violation.
• Inaccurate filing: $5,000 per violation for providing materially inaccurate information in any of the 10 data elements.
• No filing: $5,000 per violation for failing to file an ISF at all. This is the most serious non-fraud ISF violation.
• Failure to update: $5,000 for failing to update ISF information when changes occur before vessel arrival.
• Cargo holds and exams: CBP may place a Do Not Load (DNL) order, preventing the cargo from being loaded at the foreign port. If already loaded, CBP may hold the cargo at the US port for intensive examination at the importer's expense.
• Liquidated damages: In extreme cases, CBP may pursue liquidated damages against the importer's bond — up to $50,000 per continuous bond.

Who Is Responsible for ISF Filing?

The importer of record is ultimately responsible for the ISF, even if the filing is delegated to a customs broker, freight forwarder, or third-party logistics provider. If your broker files the ISF late or with incorrect information, the penalty is assessed against you as the importer — not the broker. This means importers must have systems in place to verify that ISF data is transmitted accurately and on time, regardless of who performs the actual filing.

Best Practices for ISF Compliance

• Establish standard operating procedures for ISF data collection. Require suppliers and manufacturers to provide accurate shipping information well before vessel loading.
• Build ISF filing into your purchase order process. When a PO is issued, begin collecting the 10 data elements immediately — do not wait for the cargo to be ready to ship.
• Verify HTS classifications before ISF submission. The HTS code in the ISF must match the entry — discrepancies trigger CBP alerts.
• Use a single source of truth for product data. Maintain a product master file with pre-validated HTS codes, countries of origin, and manufacturer information.
• Monitor ISF filings in real time. Use ACE reports to confirm that your broker transmitted the ISF and that CBP accepted it without errors.
• Implement a secondary review for ISF amendments. When data changes between initial filing and vessel arrival, ensure amendments are filed promptly.

How TariffPro Supports ISF Accuracy

The single most common source of ISF errors is the HTS classification code. Because the ISF is filed early in the shipment process — often before the full commercial documentation is available — importers frequently use estimated or outdated codes. TariffPro eliminates this risk by providing validated HTS classifications from your product descriptions in seconds. When you validate your classifications with TariffPro before ISF filing, you ensure consistency between the ISF and the eventual entry summary, reducing your exposure to both ISF penalties and classification-related penalties downstream. Create your free account to start validating ISF classifications today.