The Importer Security Filing (ISF), commonly known as '10+2,' is a CBP regulation that requires importers and vessel carriers to provide advance cargo information for all goods arriving in the United States by ocean vessel. Implemented under the SAFE Port Act of 2006 and codified in 19 CFR Part 149, the ISF regulation is a cornerstone of CBP's layered cargo security strategy. The filing must be submitted no later than 24 hours before the cargo is loaded onto a vessel destined for the United States, and failure to comply can result in significant monetary penalties, cargo holds, and even denial of entry.
The '10' in '10+2' refers to ten data elements that must be provided by the importer or their agent. These elements are designed to give CBP advance visibility into what goods are being shipped to the US, who is involved in the transaction, and where the goods originated. The accuracy and timeliness of these data elements are critical to CBP's ability to assess risk and target potentially dangerous or non-compliant shipments before they arrive at US ports.
The '+2' refers to two additional data elements provided by the ocean carrier rather than the importer. These are the vessel stow plan, which details where each container is positioned on the vessel, and the container status messages, which track the movement and status of containers throughout the shipping process. While importers are not responsible for filing these carrier elements, they should be aware that CBP uses this data in conjunction with the importer's ten elements to build a comprehensive risk profile for each shipment.
The ISF must be filed at least 24 hours BEFORE the cargo is laden (loaded) aboard the vessel at the foreign port. This is not 24 hours before arrival in the US. For FROB (Foreign Remaining on Board) cargo and IE (Immediate Export) cargo, the ISF must be filed 24 hours before arrival at the first US port.
The 24-hour pre-loading requirement means that importers must provide their ISF data to their customs broker or filing agent well in advance of the cargo loading date. In practice, most brokers and forwarders recommend submitting ISF information at least 72 hours before the vessel's estimated loading time to allow for data verification and correction of any errors. Late filings or amendments can trigger CBP scrutiny and may result in penalties, even if the cargo ultimately arrives without incident. ISF amendments are permitted and sometimes necessary, for example when the vessel or container number changes, but the initial filing must be made within the required timeframe.
CBP takes ISF compliance seriously and has the authority to impose penalties of up to $5,000 per violation for late, inaccurate, or missing filings. In practice, CBP has used a graduated enforcement approach, but penalties have become increasingly common as the regulation has matured. In addition to monetary penalties, CBP can place cargo on hold at the port of arrival, delaying release until the ISF is properly filed. In severe cases, CBP can deny entry of the merchandise entirely. Repeated violations can result in the importer being flagged for enhanced examination of all their shipments, creating ongoing delays and costs across their entire import program.
While the standard ISF-10 applies to most commercial ocean shipments, CBP provides a simplified ISF-5 filing option for certain categories of cargo. ISF-5 requires only five data elements and applies to goods shipped by or on behalf of US government agencies, goods intended for immediate export (IE cargo), goods transiting the US without entering commerce (T&E cargo), and Foreign Remaining on Board (FROB) cargo. The reduced data requirements for ISF-5 reflect the lower risk profile of these shipment types. Importers should consult with their customs broker to determine which ISF type applies to their specific shipments.
The ISF 10+2 filing is a non-negotiable requirement for ocean imports into the United States. While it adds an administrative step to the import process, it also creates an opportunity for importers to improve their supply chain visibility by requiring advance data collection from all parties involved in the shipment. By treating ISF compliance as an integral part of your import operations rather than a last-minute task, you can avoid penalties, minimize delays, and demonstrate to CBP that your company is a reliable and low-risk trading partner.
Camtom Team
Editorial Team
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