ISF 10+2 Filing Requirements: Elements, Deadlines and the $5,000 Claim

What are the ISF 10+2 filing requirements?

The Importer Security Filing (ISF) is the advance cargo data CBP requires for goods arriving by vessel: ten elements from the importer side under 19 CFR part 149, plus two carrier submissions, the vessel stow plan and container status messages. Most of the importer data is due 24 hours before the container is loaded at the foreign port.

Who files the ISF, and what happens if it is late?

The ISF Importer, usually the goods' owner, purchaser or consignee, or an agent such as a licensed customs broker filing for them. A missed, late or inaccurate filing can draw liquidated damages of $5,000 per violation under the importer's bond, per 19 CFR 113.62(j).

TL;DR: ISF filing requirements come down to twelve data points, two clocks and one bond condition. The importer side supplies ten elements, eight of them due 24 hours before lading at the foreign port. The carrier supplies a stow plan and container status messages. Each importer violation can cost $5,000 at face value. For an importer booking 40 ocean shipments a month, that is 40 lading deadlines a month, each one carrying a six-digit HTS number and a country of origin that should match the entry filed weeks later. GingerControl is the trade compliance AI that builds that product record: its HTS Classification Researcher reasons through the GRI and cites CROSS rulings before it settles a code, so the ISF and the entry draw on one classification instead of two.

Last updated: October 2026

What are the ten importer data elements, and where does each one come from?

19 CFR 149.3(a) lists the ten elements for shipments intended to be entered into the United States or delivered to a foreign trade zone. Each must be provided "for each good listed at the six-digit HTSUS number at the lowest bill of lading level," meaning the house bill where one exists. The regulation also requires that "the manufacturer (or supplier), country of origin, and commodity HTSUS number must be linked to one another at the line item level."

#	Element	What 19 CFR 149.3(a) asks for	Where the data usually lives	Due
1	Seller	Last known entity by whom the goods are sold or agreed to be sold	Purchase order, commercial invoice	24 hours before lading
2	Buyer	Last known entity to whom the goods are sold or agreed to be sold	Purchase order, commercial invoice	24 hours before lading
3	Importer of record number	IRS number, EIN, SSN or CBP-assigned number of the party liable for duties	Importer master data	24 hours before lading
4	Consignee number	IRS number, EIN, SSN or CBP-assigned number of the party on whose account goods ship	Importer master data	24 hours before lading
5	Manufacturer (or supplier)	Entity that last manufactures, assembles, produces or grows the goods, or the supplier of finished goods	Supplier master, factory records	24 hours before lading
6	Ship to party	First party scheduled to physically receive the goods after release	Logistics plan, warehouse routing	24 hours before lading
7	Country of origin	Country of manufacture, production or growth under U.S. import rules	Product record, origin analysis	24 hours before lading
8	Commodity HTSUS number	HTS number to at least six digits, up to ten	Product record, classification file	24 hours before lading
9	Container stuffing location	Where the goods were physically stuffed into the container	Forwarder or origin agent	24 hours before U.S. arrival
10	Consolidator (stuffer)	Party who stuffed the container or arranged the stuffing	Forwarder or origin agent	24 hours before U.S. arrival

Bottom line: For compliance teams assembling ISF data across dozens of suppliers, elements 1 through 6 are commercial facts that sit in purchasing and logistics systems, while elements 7 and 8 are legal determinations. Origin and HTS classification are the two elements where a wrong answer is an analysis error, not a typo.

Two details in the regulation change how teams should source the data. First, elements 5 through 8 are "flexible" under 19 CFR 149.2(f): the ISF Importer may send the best data available at the time, then must update it as more accurate information arrives, and no later than 24 hours before arrival at a U.S. port. Second, for elements 3 and 4 the regulation accepts only government identifiers, so the importer's own records are the only source.

What are the two carrier elements?

The "+2" belongs to the ocean carrier, not the importer. Both requirements sit in 19 CFR part 4, alongside the carrier's existing manifest obligations.

Carrier element	Regulation	What it contains	Deadline	Liquidated damages on the carrier bond
Vessel stow plan	19 CFR 4.7c	Vessel name and IMO number, operator, voyage, and for each container its operator, equipment number, size and type, stow position, hazmat code, ports of lading and discharge	No later than 48 hours after departure from the last foreign port, or before arrival for voyages under 48 hours	$50,000 per vessel arrival, 19 CFR 113.64(g)
Container status messages	19 CFR 4.7d	Events such as booking confirmation, terminal gate inspection, gate in and gate out, loading and unloading, vessel departure and arrival	No later than 24 hours after the message is entered in the carrier's tracking system	$5,000 per violation, up to $100,000 per vessel arrival, 19 CFR 113.64(h)

Bottom line: For importers and their compliance teams, the carrier elements are context, not a task. They explain why CBP can see where a container is stowed and when it moved, which is the picture your ten elements are checked against.

One limit worth knowing: 19 CFR 4.7d states "there is no requirement that a carrier create or collect any CSMs" it does not already create or collect in its own equipment tracking system. The rule makes carriers share what they already track. It does not make them track more.

When is the ISF due, and what does "24 hours before lading" mean?

19 CFR 149.2(b) sets two clocks:

1. Elements 1 through 8 are due "no later than 24 hours before the cargo is laden aboard the vessel at the foreign port." The trigger is loading at origin, not departure and not U.S. arrival. If the container is laden at the origin port on Thursday at 14:00, the filing is due by Wednesday at 14:00.
2. Elements 9 and 10, stuffing location and consolidator, are due "as early as possible, in no event later than 24 hours prior to arrival in a United States port," or upon lading where the voyage to the nearest U.S. port is under 24 hours.

Three more obligations in the same section run after the first filing:

• Update. Under 149.2(d), the filer "must update the filing if, after the filing is submitted and before the goods enter the limits of a port in the United States, any of the information submitted changes or more accurate information becomes available."
• Withdrawal. Under 149.2(e), if the goods are no longer intended to be imported, the filer must withdraw the ISF and give CBP the reason.
• Verification. Under 149.2(c), where the filer receives data from another party and cannot reasonably verify it, CBP "will permit the party to electronically present the information on the basis of what the party reasonably believes to be true."

Scope matters as much as timing. Part 149 applies to "cargo arriving by vessel." Bulk cargo that is exempt from the carrier's 24-hour manifest rule is also exempt from ISF under 149.4(a). Qualifying break bulk cargo keeps the filing but moves the deadline to 24 hours before arrival in the United States under 149.4(b). Shipments that stay on board as foreign cargo, or that move in-bond for immediate exportation or transportation and exportation, use a shorter five-element set under 149.3(b): booking party, foreign port of unlading, place of delivery, ship to party and HTS number.

CBP's Importer Security Filing 10+2 page states the rule went into effect on January 26, 2009. The regulation's own compliance date, in 149.2(g), is January 26, 2010.

Who is legally responsible for the ISF, the importer or the broker?

The ISF Importer, and the definition is functional rather than a job title. 19 CFR 149.1(a) defines the ISF Importer as "the party causing goods to arrive within the limits of a port in the United States by vessel." For ordinary imports, that is "the goods' owner, purchaser, consignee, or agent such as a licensed customs broker." For foreign cargo remaining on board, it is the carrier or NVOCC.

Four rules in 19 CFR 149.5 decide who can do what:

Question	What part 149 says
Can an agent file?	Yes. An authorized agent may file once it has set up the communication protocol CBP requires.
Does the agent need a broker licence?	Not for the ISF alone. A licence, or acting as importer on its own behalf, is required only where the ISF and the entry or entry summary go in a single transmission.
Whose bond is on the line?	The ISF Importer must hold a qualifying bond. If it does not, the agent filing for it may post the agent's own bond.
What records must the agent keep?	Powers of attorney in English until revoked, and revoked powers plus revocation letters for five years.

Bottom line: For an importer whose forwarder files 30 or more ISFs a month, outsourcing the transmission does not outsource the data. The seller, manufacturer, origin and HTS number still come from your purchase orders and your product records, and the bond that answers for a violation is usually yours.

GingerControl builds the classification and product data that an ISF draws on. It does not transmit ISFs, file entries, act as importer of record or give legal advice. The filing stays with the importer or the agent it authorizes.

What does an ISF violation cost?

ISF exposure runs through the customs bond, not a separate penalty schedule. The basic importation and entry bond conditions in 19 CFR 113.62(j) read: "If the principal defaults with regard to any obligation, the principal and surety (jointly and severally) agree to pay liquidated damages of $5,000 for each violation." The international carrier bond in 19 CFR 113.64(f) carries the same $5,000 figure for a carrier that elects to file the ISF.

The arithmetic is per violation, so frequency matters more than any single miss. A team that files three ISFs late in a quarter is looking at $15,000 in claims at face value ($5,000 x 3), before any relief CBP may grant. A process gap that repeats on every booking for one supplier multiplies the same way.

Money is not the only cost. CBP's own ISF page warns that "Failure to comply with the rule could ultimately result in monetary penalties, increased inspections and delay of cargo." Inspections and cargo delay cost time at the terminal, and for a production line waiting on parts, time is often the larger cost.

Responding to a claim is a separate job from avoiding one, and it runs on records: proof of when each transmission went in, the data available at the time, and what was corrected. Keep those records whether or not a claim ever arrives, and take any claim to your licensed broker or counsel.

How does the ISF HTS number tie to entry classification?

This is where ISF stops being a logistics task and becomes a classification task. Element 8 in 19 CFR 149.3(a)(8) reads: "The HTSUS number must be provided to the six-digit level. The HTSUS number may be provided up to the 10-digit level. This element can only be used for entry purposes if it is provided at the 10-digit level or greater by the importer of record or its licensed customs broker."

Three consequences follow:

1. The six digits are an early statement of the entry. The ISF goes in before the goods load. The entry follows after arrival at ten digits. The first six digits of the entry classification and the ISF number describe the same goods, so a team that classifies twice, once quickly for the ISF and once carefully for the entry, has created two answers to one question.
2. Origin and manufacturer are tied to the code. Because 149.3(a) requires the manufacturer, origin and HTS number to be linked at line level, a multi-supplier SKU with goods from two factories in two countries needs two lines, not one.
3. The six-digit line is also a legal boundary. As our post on when HTS classification requires a customs broker explains, six-digit classification for ISF sits on one side of the customs business line and ten-digit classification for entry sits on the other. Under 149.5(a), filing the ISF and the entry in a single transmission under 149.6 is reserved to an importer acting on its own behalf or a licensed customs broker.

Quotable insight: An ISF is the first time an importer tells CBP what the goods are, and the entry is the second. Part 149 links manufacturer, origin and HTS number at line level, so the ISF is in effect a six-digit preview of the entry. When the two disagree, the problem is rarely the filer. It is a product record that let two people classify the same SKU separately.

For SKUs that sit near a heading boundary, such as composite goods where GRI 3(b) essential character decides the heading, the six-digit answer is the hard part, not the formatting. Those are the products where an ISF built from a supplier's commercial description is most likely to drift from the entry your broker files.

How do you keep ISF data accurate across a catalog that changes every week?

Treat the ISF as an output of master data, not a form someone fills in at booking. A practical sequence:

1. Classify before you book. Every SKU that can ship by ocean should carry a reviewed HTS classification and origin before the first purchase order, not at the 24-hour mark.
2. Key the record by SKU and factory. Because origin and manufacturer link to the HTS number at line level, the product record should carry one row per SKU and source, so a second factory triggers a second origin determination.
3. Feed the ISF and the entry from the same record. The ISF filer takes the first six digits; the broker takes ten. Neither re-keys.
4. Log every update. Under 149.2(d), changes before arrival must be filed as updates. Keep the timestamp and the reason, because that record is what a relief request will need.
5. Reconcile after release. Compare the ISF lines with the entry summary lines each month. Any six-digit difference is a classification question for your broker, and a signal that the product record has a gap. Our guide to why CBP holds shipments shows how ISF problems surface at the terminal.

Bond sizing and fees sit alongside this work. The ISF bond question for single shipments is covered in single entry bond vs continuous bond, and the per-filing service charge is broken out in customs fees explained. For where ISF sits in the end-to-end sequence, see the customs clearance process.

Where ISF classification fits in your pre-lading workflow

The HTS number and origin are the two ISF elements that require analysis rather than lookup, and they should be settled before the booking. GingerControl's HTS Classification Researcher follows GRI logic and asks clarifying questions before it assigns a classification, reading similar CROSS rulings during the analysis and producing a reasoning report grounded in Section and Chapter Notes. GingerControl is an HTS Classification Researcher: it follows the reasoning process a licensed customs broker uses, but the final classification decision benefits from professional judgment, and its documentation supports that decision rather than providing legal advice or replacing licensed customs expertise.

References

[REF 1] eCFR, 19 CFR part 149, Importer Security Filing (current as of October 5, 2026) Data cited: ISF Importer definition (149.1), timing, update, withdrawal, flexible elements and compliance date (149.2), the ten and five data elements and HTS rules (149.3), bulk and break bulk (149.4), agents, bonds and powers of attorney (149.5), single transmission (149.6) Source: 19 CFR part 149

[REF 2] eCFR, 19 CFR 113.62, basic importation and entry bond conditions Data cited: $5,000 liquidated damages per ISF violation, paragraph (j) Source: 19 CFR 113.62

[REF 3] eCFR, 19 CFR 113.64, international carrier bond conditions Data cited: $5,000 per ISF violation by a carrier filer (f), $50,000 per vessel arrival for stow plans (g), $5,000 per violation up to $100,000 per vessel arrival for container status messages (h) Source: 19 CFR 113.64

[REF 4] eCFR, 19 CFR 4.7c and 4.7d, vessel stow plan and container status messages Data cited: stow plan contents and 48-hour deadline; container status message events and 24-hour deadline Source: 19 CFR part 4

[REF 5] U.S. Customs and Border Protection, Importer Security Filing 10+2 Data cited: effective date of January 26, 2009, and consequences of non-compliance Source: CBP Importer Security Filing 10+2

[REF 6] Federal Register, Importer Security Filing and Additional Carrier Requirements, CBP Dec. 08-46, 73 FR 71730, November 25, 2008 Data cited: source rule for part 149 and sections 4.7c and 4.7d Source: 73 FR 71730