ISF 10+2:
The Complete Filing Guide

The Importer Security Filing (ISF), also called "10+2" because of its data structure, is the security pre-arrival filing every US ocean importer has to submit. It is one of the most-missed filings in customs and one of the easiest CBP penalty targets.

If you are about to bring in your first container, ISF is the document that has to be filed before the container is even on the boat. Late, missing, or incorrect ISF means CBP holds your container on arrival, every time.

The short version

The 10 importer elements

The 10 elements come from the importer of record (or their broker on their behalf):

1. Seller name and address: the entity selling the goods
2. Buyer name and address: the entity buying the goods
3. Importer of Record number: the IOR's EIN, SSN, or CBP-assigned number
4. Consignee number(s): the consignee's identifier (IRS, SSN, or CBP-assigned)
5. Manufacturer (or supplier) name and address: where the goods were made
6. Ship-to name and address: where the goods are going (consignee's address)
7. Country of origin: where the goods were manufactured
8. HTS number: the Harmonized Tariff Schedule classification (6-digit minimum)
9. Container stuffing location: where the container was loaded
10. Consolidator (stuffer) name and address: who did the loading

The 2 carrier elements

The 2 elements come from the ocean carrier:

1. Vessel stow plan: where the container sits on the vessel
2. Container status messages: updates throughout the voyage

The carrier transmits these automatically. The importer does not file them. They are listed here for completeness, but for practical purposes, importers care about the 10 importer elements.

When ISF is due

For most trans-Pacific shipments, that means ISF needs to be filed 2 to 3 days before the vessel sails from China. Practically, your broker files ISF immediately after the commercial invoice and packing list are ready, which is usually a week before sailing.

Penalties for getting it wrong

CBP can assess up to $5,000 per ISF violation. Common violations:

• Late filing: ISF transmitted less than 24 hours before loading
• Inaccurate data: one of the 10 elements is wrong
• Incomplete data: missing element
• No filing: ISF never submitted

The mitigation policy lets CBP assess less than $5,000 for first violations and good-faith errors, but consistent or willful violations get hit harder. In practice, CBP enforcement is more aggressive on:

• Repeat offenders
• Importers with no documented filing process
• Shipments where the late ISF appears to be hiding something

The most-violated elements

From the field, the elements that get filings rejected most:

Manufacturer name and address

Importers often confuse "manufacturer" with "supplier" or "seller." The manufacturer is whoever actually made the goods. If you bought from a trading company, the trading company is the seller, but the factory that produced the goods is the manufacturer. Both names go on the ISF, in different fields.

Country of origin

Origin is where the goods were "substantially transformed," not where they were shipped from. Cargo shipped from Vietnam might be of Chinese origin if the substantial transformation happened in China. Misdeclaring origin to dodge Section 301 is now a major CBP enforcement target.

HTS number

The 6-digit HTS code on ISF must match the 10-digit code on the entry. If your broker uses different codes, ISF gets flagged. Coordinate ISF data and entry data ahead of time.

Container stuffing location and consolidator

If the container was stuffed at a CFS (Container Freight Station) rather than the factory, the CFS name and address are required, not the factory's. This trips up importers who use LCL or who use a consolidator at origin.

Who files ISF

The importer of record is legally responsible for ISF, but the actual filing is almost always done by a licensed customs broker on their behalf. The broker needs a Power of Attorney from the IOR (a standard form) to file.

If you are setting up a new import operation, file the POA the same day you sign up your broker. ISF cannot be filed without it.

ISF for LCL (Less than Container Load)

LCL shipments still require ISF. Each consignee with cargo in a consolidated container is responsible for their own ISF. The consolidator (NVOCC) files the carrier elements, but the importer elements remain the importer's responsibility.

Amending an ISF

You can amend an ISF after submission. CBP does not penalize good-faith amendments made before the vessel arrives. Amendments after arrival are penalized differently depending on the timing and the nature of the change.

Common amendment scenarios:

• HTS code refined as the entry is prepared (allowed before arrival)
• Container number changed at the last minute (allowed)
• Supplier substituted post-loading (penalized, suspect)
• Origin change post-arrival (heavy scrutiny, possible audit)

How brokers file ISF

Brokers file electronically through the Automated Broker Interface (ABI) or AMS. CBP confirms receipt with an acceptance message. If any element fails validation, the broker gets a rejection and resubmits.

Typical broker fee for ISF filing: $35 to $75 per filing. Some brokers bundle ISF with the entry fee.

The Syqora workflow

For our clients, we collect commercial invoice and packing list data at the time of supplier confirmation, before the vessel even has a sailing schedule. Our customs broker partner pre-validates the 10 ISF elements against the commercial documents. ISF goes out 5+ days before loading on average, well within the 24-hour rule. Our ISF rejection rate is under 2%, vs the industry average of around 9%.

Bottom line

ISF is straightforward when you have a process and disastrous when you do not. The 10 data elements come straight from your commercial invoice and packing list. Get them organized at the time of supplier confirmation, file 5+ days before vessel loading, and verify the manufacturer (not just the seller) is named correctly.

Do not file ISF in a panic 24 hours before loading. Do not delegate ISF to your supplier or freight forwarder without a customs broker partner. And do not assume the rules are flexible: $5,000 per violation adds up fast on a regular import program.

Further reading

• Customs holds and CBP exams: what triggers them
• CBP Form 5106 complete filing guide
• Import duties from China to the USA
• FOB vs DDP: who is the Importer of Record?