A Comprehensive Guide to ISF Importer Security Filing

Introduction and Background

The Importer Security Filing (ISF), commonly known as the "ISF Filing 10+2," is a regulation enforced by U.S. Customs and Border Protection (CBP) that mandates the advance submission of cargo data for maritime shipments. Implemented on January 26, 2009, the rule requires 10 data elements from importers and two additional elements from ocean carriers to enhance security screening before goods arrive in the United States.

The ISF must be filed electronically for all ocean cargo destined for the U.S., typically through systems like the Automated Manifest System (AMS) or the Automated Broker Interface (ABI). The filing is linked to the shipment's AMS bill of lading within the AMS Ocean(ACE Ocean) system.

When ISF need to be filed?

• Containerized Cargo:? Must be filed 24 hours before the cargo is loaded onto the vessel at the foreign port.
• Break-bulk Cargo:? Must be filed 24 hours before the vessel's arrival at the first U.S. port.
• Bulk Cargo:? Exempt from ISF requirements.

Who is Responsible for Filing the ISF?

• Import into US:The "ISF Importer" is the party responsible for ensuring the filing is submitted. This entity is typically the owner, purchaser, consignee, or their authorized agent (such as a licensed customs broker, or the party who booked the shipping space). The ISF Importer is legally defined as the party primarily responsible for the cargo's arrival into the U.S.
• FROB or In-transit:For specific cargo types like goods remaining on board (FROB) or in-transit shipments, the carrier is usually considered the ISF Importer. These shipments have a simplified filing requirement of 5 data elements, known as ISF 5.

Importer Requirements and Data Elements

ISF 10(10 Data ElementsImport into US)

Importers can designate a licensed customs broker or the party who booked the shipping space to file the ISF 10 on their behalf. The filing party is obligated to update the ISF with any changes or more precise information as it becomes available, up until 24 hours before the cargo arrives at a U.S. port.
For typical import shipments, the following ten data points are required:

1. Importer of Record Number
2. Consignee Number(US IRS,SSN, CBP Assign Number)
3. Seller (Owner) name/address
4. Buyer (Owner) name/address
5. Ship to Party
6. Manufacturer (supplier) name and address
7. Country of Origin
8. Commodity HTS: this is the US HTS
9. Container Stuffing Location: Address where the container was stuffed
10. Consolidator (Stuffer) name/address

For more information about ISF 5, please refer to ISF10 Filing Content (Imported into US)

ISF 5 (5 Data Elements for FROB/In-Transit)

1. Booking Party Name/Address
2. Ship To Party
3. Commodity HTS Number
4. Foreign Port of Unlading
5. Place of Delivery

For more information about ISF 5, please refer to ISF5 Filing Content (FROB US)

Flexible Filing Options

The ISF rule provides flexibility for data that may not be immediately available:

• FR = Flexible Range:? A range of data for the Manufacturer, Ship To party, Country of Origin, or Commodity HTSUS number has been provided. The ISF must be updated as soon as better information becomes available, but never later than 24 hours prior to arrival. If "FR" is used, CBP expects to receive a timely update.
• FT = Flexible Timing:? The CS (Consolidator) and or LG (Stuffing location) has not been provided. The ISF must be updated as soon as better information becomes available, but never later than 24 hours prior to arrival. If "FT" is used, CBP expects to receive a timely update.
• FX = Flexible Range and Flexible Timing:? A range of data as described in "FR" has been provided and the CS (Consolidator) and or LG (Stuffing location) has not been provided. The ISF must be updated at a later date as soon as better information becomes available, but in no case later than 24 hours prior to arrival. If "FX" is used, CBP expects to receive a timely update.

Carrier Requirements 

Carriers have two primary obligations under the ISF rule:

Vessel Stow Plan

Vessel Stow Plan must be submitted to CBP no later than 48 hours after the vessel departs from a foreign port bound for the U.S. This plan details the position of each container on the vessel and includes information like vessel details, container numbers, ports of lading/discharge, and hazardous materials codes. Break-bulk and bulk carriers are generally exempt.

Container Status Messages

Carriers must daily report specific status events for containers destined for the U.S., such as :

• When the carrier confirms that their booking concerning a container heading for a US port is complete.
• When the terminal gate inspection of a vessel set to arrive in a US port is completed.
• When a container headed to a US port departs or arrives at a facility.
• When a container headed to a port in the US is unloaded or loaded from a means of transport.
• When a ship conveying a container headed to a US port arrives or departs from a port.
• When a container headed to a port in the US is subjected to intra-terminal movement.
• When a container headed to an American port by ship is ordered stripped or stuffed
• When a container headed to an American port by ship is confirmed stripped or stuffed.
• When a container headed to a port in the US is grounded for major repairs.

ISF Violations and Enforcement

CBP enforces ISF compliance strictly and may assess liquidated damages and other penalties for violations, including:

• ISF is not filed;
• Late filing of an ISF;
• Inaccurate filing: Submitting an inaccurate or incomplete filing;
• Failing to update an ISF with new information;
• Failure to cancel an ISF that is no longer valid;