The Importer Security Filing (ISF), also called 10+2, must be submitted to CBP at least 24 hours before cargo is loaded onto a vessel at the foreign port. Late, inaccurate, or missing filings can trigger $5,000 in liquidated damages per violation, cargo holds, physical examinations, and seizure. ISF applies to all ocean freight entering the United States. In the current enforcement environment, CBP is actively assessing penalties, and repeated violations increase your risk score on every future shipment. Here is what is required, what goes wrong, and how to never miss a deadline.
Key Takeaways
ISF is mandatory for all cargo arriving in the United States by ocean vessel. It does not apply to air, truck, or rail shipments.
The filing deadline is at least 24 hours before cargo is loaded onto the vessel at the foreign port of departure, not 24 hours before arrival in the United States.
The penalty for late, inaccurate, or missing ISF filings is $5,000 in liquidated damages per violation. Total exposure can reach $10,000 per filing.
First-time violations may be mitigated to $1,000 to $2,000 depending on circumstances. C-TPAT members receive up to 50% additional penalty mitigation.
CBP can hold your cargo, issue a Do Not Load message to the carrier, withhold permission to unload, or place goods in General Order (government custody) for ISF noncompliance.
The importer of record is legally responsible for ISF accuracy, even when a customs broker or freight forwarder files on their behalf.
CBP ports are now directed to issue liquidated damages within 90 days of learning of a violation, and the previous "three strikes" practice has been eliminated.
What Is an ISF Filing?
An Importer Security Filing (ISF) is a mandatory electronic submission that U.S. importers must file with Customs and Border Protection for all ocean cargo shipments bound for the United States. It is commonly called "10+2" because the importer provides 10 data elements and the ocean carrier provides 2 additional elements.
The short answer is: ISF tells CBP what is on the ship before it leaves the foreign port. It is a security requirement, not a customs entry. The customs entry (Form 3461/7501) is a separate process that happens when goods arrive.
Key definition: ISF Importer is the party causing the goods to arrive within the limits of a U.S. port by vessel. This is typically the goods' owner, purchaser, consignee, or authorized agent. The ISF Importer bears legal responsibility for the filing.
The ISF requirement was established under the Safe Port Act of 2006 and the Trade Act of 2002. The final rule went into effect on January 26, 2009. CBP began enforcing penalties in May 2015 and has progressively tightened enforcement since then.
What Are the 10 Data Elements the Importer Must Provide?
The ISF Importer (or their customs broker) must submit the following 10 data elements at least 24 hours before the cargo is loaded onto the vessel.
| # | Data Element | What It Means |
|---|---|---|
| 1 | Seller name and address | The entity that sold the goods |
| 2 | Buyer name and address | The entity purchasing the goods (typically the U.S. importer) |
| 3 | Importer of record number | IRS EIN or CBP-assigned number |
| 4 | Consignee number | The party to whom the goods are being shipped |
| 5 | Manufacturer (or supplier) name and address | The actual factory that produced the goods, not the trading company |
| 6 | Ship-to party | The physical location where goods will be delivered |
| 7 | Country of origin | Where the goods were manufactured or produced |
| 8 | Commodity HTS number | At minimum a 6-digit Harmonized Tariff Schedule code |
| 9 | Container stuffing location | Where the goods were loaded into the container |
| 10 | Consolidator name and address | The party that stuffed the container or arranged for the goods to be loaded |
The ocean carrier separately provides the vessel stow plan and container status messages (the "+2" in 10+2).
When Exactly Must the ISF Be Filed?
The ISF must be filed no later than 24 hours before the cargo is loaded onto the vessel at the foreign port of departure.
The short answer is: the clock starts at vessel loading, not vessel departure, and not vessel arrival. If your cargo is loaded onto a ship in Shanghai at 6:00 PM on Monday, your ISF must have been filed by 6:00 PM on Sunday at the latest.
CBP uses the first bill of lading file date as a "proxy indicator" of ISF timeliness, since the bill of lading must also be filed at least 24 hours before loading. CBP now uses vessel departure date minus 24 hours to assess ISF timeliness.
If shipment details change after filing (such as a change in consignee, manufacturer, or routing), the ISF must be updated before the vessel arrives in the United States. Brokers may charge an additional $20 to $40 per amendment.
What Happens If You File Late or Not at All?
CBP has multiple enforcement tools for ISF noncompliance, and the consequences escalate with severity and frequency.
Liquidated damages. The standard penalty is $5,000 per ISF violation. Total potential exposure can reach $10,000 per filing. Violations include failure to file, late filing, inaccurate filing, and failure to withdraw an invalid filing.
First-time mitigation. First violations may be mitigated to $1,000 to $2,000 depending on mitigating circumstances, such as evidence of progress in implementing ISF compliance. C-TPAT members receive up to 50% additional mitigation.
Second and subsequent violations. CBP may cancel the liquidated damages case for payment of $2,500. There is no longer a "three strikes" policy. Ports are directed to issue liquidated damages within 90 days of discovering the violation.
Cargo holds. CBP can place a hold on your container, preventing delivery until the ISF issue is resolved. Storage charges at the port accumulate at $150 to $300 per day while the goods sit.
Do Not Load (DNL) message. For complete failure to file, CBP can send a Do Not Load directive to the carrier at the foreign port, preventing your cargo from being loaded onto the vessel at all.
Seizure and General Order. In severe cases, CBP can withhold customs release, allowing the goods to move into General Order (government custody). The importer must then petition for release and may face additional storage and handling charges.
Increased targeting. Repeated ISF violations raise your CBP risk score. Higher risk scores mean more frequent physical examinations on future shipments, which add $1,000 to $5,000 in exam fees plus 5 to 15 business days of delay per incident. This cascading effect means one ISF mistake can increase costs and delays on shipments that have nothing wrong with them.
What Are the Most Common ISF Filing Mistakes?
1. Filing After the Deadline
The short answer is: this is the most frequent violation, and it is almost always preventable.
Late filing usually results from delays in receiving booking confirmations, slow communication between the importer and overseas supplier, or waiting until the last minute to engage the customs broker. The fix is procedural: trigger the ISF filing as soon as the purchase order is placed and the booking is confirmed, not when the shipping documents arrive.
2. Using the Trading Company Instead of the Actual Manufacturer
CBP requires the name and address of the actual factory that produced the goods, not the trading company or middleman that arranged the sale. Many importers provide their supplier's name without verifying whether that entity is the manufacturer or just the seller. CBP specifically scrutinizes this field and can flag shipments for examination when the manufacturer data does not match their intelligence.
3. Incorrect or Missing Bill of Lading Numbers
The bill of lading number on the ISF must match the bill of lading filed by the carrier. Mismatches trigger automated flags. Ocean carriers are sometimes slow to provide bill numbers, which delays the ISF filing. Establish a process with your forwarder to obtain bill numbers as early as possible.
4. Wrong HTS Codes
An inaccurate HTS code on the ISF can flag your shipment for examination. While the ISF only requires a 6-digit code (compared to the 10-digit code required on the customs entry), even a 6-digit error can place your shipment in a risk category that triggers inspection. Use at least 6 digits, and use 10 digits when available for better accuracy.
5. Failing to Update or Withdraw an Invalid ISF
If an order is cancelled, the routing changes significantly, or the shipment details change materially, the ISF must be updated or withdrawn. Failing to withdraw an invalid ISF is itself a violation that can trigger liquidated damages. Many importers do not realize this obligation exists.
Does ISF Apply to All Shipments?
No. ISF applies only to ocean cargo entering the United States by vessel.
| Shipment Type | ISF Required? | Alternative Requirement |
|---|---|---|
| Ocean freight (FCL or LCL) | Yes, ISF-10 | N/A |
| Air freight | No | Air Cargo Advance Screening (ACAS) |
| Truck from Canada/Mexico | No | ACE e-manifest |
| Rail | No | ACE e-manifest |
| Bulk ocean cargo | Generally exempt | Varies by commodity |
| Transit/FTZ shipments | Simplified ISF-5 | Reduced data elements |
Key definition: ISF-5 is a simplified version of the ISF used for goods transiting through the U.S. to another country or entering a Foreign Trade Zone. It requires only 5 data elements instead of 10.
How Much Does ISF Filing Cost?
The filing itself is not expensive. The penalties for getting it wrong are.
| Cost Item | Typical Range |
|---|---|
| Customs broker ISF filing fee | $30 to $80 per filing |
| Single-use ISF bond (if needed) | $50 to $75 |
| ISF amendment fee | $20 to $40 per change |
| Late filing penalty (first violation) | $1,000 to $2,000 (mitigated) |
| Late filing penalty (subsequent) | $2,500 to $5,000 |
| Cargo hold storage charges | $150 to $300 per day |
| Physical examination fee | $1,000 to $5,000 |
The cost of a properly filed ISF is under $100. The cost of a missed or late ISF can exceed $10,000 when penalties, storage, and exam fees are combined. The ROI on getting this right is among the highest of any compliance requirement.
How to Build an ISF Process That Never Misses a Deadline
1. Trigger the Filing at Purchase Order, Not at Shipment
Do not wait for the shipping documents to begin the ISF process. As soon as a purchase order is placed and a booking is confirmed, your broker should have enough information to begin assembling the 10 data elements. The earlier you start, the more time you have to verify manufacturer details, HTS codes, and bill of lading numbers.
2. Require Manufacturer Details in Every Purchase Order
Make the actual manufacturer's name and address a required field in your purchase order template. If your supplier is a trading company, require them to provide the factory information as a condition of the order. This eliminates the most common data gap in ISF filings.
3. Establish a Communication Protocol With Your Broker
Your broker needs booking confirmation, bill of lading numbers, and supplier/manufacturer details with enough lead time to file 24 hours before loading. Define who sends what, to whom, and by when. A shared tracking spreadsheet or integration between your order management system and your broker's filing platform eliminates manual handoffs and missed deadlines.
4. Audit Your ISF Compliance Quarterly
Pull your ISF filing records and compare filing timestamps against vessel loading dates. Identify any filings that were late, amended, or incomplete. Track the frequency of amendments and the data elements that most often require correction. Use this data to fix the upstream process, whether that is a slow supplier, an unreliable carrier, or an internal communication gap.
5. Enroll in C-TPAT for Penalty Mitigation
If your company qualifies for the Customs-Trade Partnership Against Terrorism program, enrollment provides up to 50% mitigation on ISF penalties and reduces the likelihood of physical examinations across all your shipments. For importers with significant ocean freight volumes, the C-TPAT benefits extend well beyond ISF.
Frequently Asked Questions
What is ISF filing?
ISF (Importer Security Filing), also called 10+2, is a mandatory electronic filing with CBP required for all ocean cargo entering the United States. The importer provides 10 data elements and the carrier provides 2. It must be filed at least 24 hours before cargo is loaded onto the vessel at the foreign port.
How much is the ISF late filing penalty?
The standard liquidated damages amount is $5,000 per violation, with total potential exposure of $10,000 per filing. First-time violations may be mitigated to $1,000 to $2,000. C-TPAT members receive up to 50% additional mitigation.
When must the ISF be filed?
At least 24 hours before cargo is loaded onto the vessel at the foreign port of departure. Not 24 hours before departure, and not 24 hours before arrival in the United States.
Does ISF apply to air shipments?
No. ISF applies only to ocean vessel cargo. Air shipments are covered by the Air Cargo Advance Screening (ACAS) program. Truck and rail shipments are covered by ACE e-manifest requirements.
Who is responsible for filing the ISF?
The ISF Importer, which is the party causing goods to arrive at a U.S. port by vessel. This is typically the importer of record, buyer, or consignee. A customs broker or forwarder may file on the importer's behalf, but the ISF Importer retains legal responsibility.
What happens if I do not file an ISF at all?
CBP can issue a Do Not Load message to the carrier, withhold permission to unload, place goods in General Order (government custody), seize the shipment, or assess $5,000 to $10,000 in liquidated damages.
Can CBP hold my cargo for an ISF violation?
Yes. CBP can place a hold on your container, preventing delivery until the issue is resolved. Storage charges of $150 to $300 per day accumulate during the hold.
How much does ISF filing cost?
Customs broker fees for ISF filing typically range from $30 to $80 per shipment. A single-use ISF bond costs $50 to $75 if needed. Amendments are $20 to $40 each.
What is the difference between ISF-10 and ISF-5?
ISF-10 is the standard filing for goods destined for U.S. consumption, requiring 10 data elements from the importer. ISF-5 is a simplified filing for goods in transit through the U.S. or entering a Foreign Trade Zone, requiring only 5 elements.
Do ISF violations affect my future shipments?
Yes. Repeated ISF violations increase your CBP risk score, which raises the probability of physical examinations, cargo holds, and enhanced scrutiny on all future shipments, even those with no ISF issues.
How long must I keep ISF records?
CBP requires importers to retain ISF records for at least five years. Records must be available for review in the event of an audit or compliance check.
Can I correct an ISF after filing?
Yes, and you should. If shipment details change, the ISF must be updated before the vessel arrives in the U.S. However, amendments after the 24-hour deadline do not retroactively cure a late filing. An ISF that was timely but later amended is treated differently from one that was filed late in the first place.
This guide reflects ISF filing requirements and CBP enforcement practices as of April 3, 2026. ISF applies to all ocean cargo entering the United States regardless of value, commodity, or trade program. Importers should coordinate ISF filing with their customs broker and monitor CBP Cargo Systems Messaging Service (CSMS) for updates. For related compliance topics, see our guides on customs audits, HTS classification errors, and the importer's 90-day compliance calendar.
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