Importer Security Filing: ISF 10+2 Basics | JustForPetStore
An importer security filing (ISF, or “10+2”) is the electronic data set U.S. Customs and Border Protection requires for ocean cargo before it is loaded. Per CBP, it must be filed no later than 24 hours before lading, and inaccurate, incomplete or late filings can draw $5,000 in liquidated damages per violation. Small importers almost always file through a licensed broker.
What is an importer security filing?
The ISF is an advance cargo data requirement, not an entry. Its purpose is to give CBP time to assess risk before a container reaches U.S. water, and it exists separately from the customs entry you file when the goods arrive. You cannot file an entry without a valid ISF on record.
The nickname “10+2” describes the structure. The importer supplies 10 data elements. The ocean carrier supplies two more: the vessel stow plan and container status messages. The requirement originates from the Security and Accountability for Every Port Act of 2006 and is codified in 19 CFR Part 149, which sets out who must file, what must be filed, when, and what the exemptions are.
One scope point trips up new importers: the ISF applies to cargo arriving by vessel. Air freight, truck and rail shipments are not subject to it, though they have their own advance data rules.
Who has to file the ISF, and when?
The ISF Importer is the party causing the goods to arrive within the limits of a U.S. port by vessel — in practice, the importer of record or the party acting for them. Legal responsibility stays with the importer even when someone else transmits the data.
Timing is where shipments go wrong. Per CBP guidance, eight of the ten elements must be submitted no later than 24 hours before the cargo is laden aboard the vessel at the foreign port:
- Seller
- Buyer
- Importer of record number / FTZ applicant identification number
- Consignee number(s)
- Manufacturer (or supplier)
- Ship to party
- Country of origin
- Commodity Harmonized Tariff Schedule of the United States (HTSUS) number
The remaining two — container stuffing location and consolidator (stuffer) — must be submitted as early as possible and no later than 24 hours before the vessel arrives at a U.S. port.
Note what the clock is not. It is not 24 hours before sailing and it is not 24 hours before arrival. It is 24 hours before loading, which in practice can be 48 to 72 hours before the vessel departs and two to four weeks before it reaches the U.S. Build your data collection backwards from the carrier’s cargo cut-off, then add a day.
What are the 10 importer data elements in an ISF?
The full list, with the field most often filled in wrongly:
| Element | Common mistake |
|---|---|
| Seller | Naming the factory when the seller is a trading company |
| Buyer | Naming the U.S. entity when the buying entity is an overseas parent |
| Importer of record number | Using a number not yet on file with CBP |
| Consignee number(s) | Assuming it is always the same as the importer of record |
| Manufacturer (or supplier) | Naming the trading company instead of the actual factory |
| Ship to party | Giving the final customer instead of the first delivery point |
| Country of origin | Giving the port of shipment rather than where goods were made |
| Commodity HTSUS number | Using fewer than six digits |
| Container stuffing location | Leaving the CFS address off an LCL shipment |
| Consolidator (stuffer) | Leaving blank when a forwarder stuffed the container |
Four of these — manufacturer, ship to party, country of origin and commodity HTSUS number — have flexible treatment. You submit the best information reasonably available and then update the filing as the details firm up, with updates due no later than 24 hours before the vessel arrives at a U.S. port. The other elements must be accurate at first filing; placeholder data does not satisfy the rule.
The importer of record and consignee numbers have to be on file with CBP before you can use them in a filing, so sort that out with your broker well before your first booking.
What happens if an ISF is late or wrong?
Per CBP, liquidated damages of $5,000 per violation can be issued for a filing that is inaccurate, incomplete or untimely. The consequences that hurt a small importer more than the penalty itself are operational: CBP can issue a do-not-load order, hold the container at the port, or select it for examination. Storage and demurrage accrue daily while the container sits, and a missed seasonal window costs more than the fine.
Because a single shipment can generate multiple violations, the exposure scales with shipment count. A small importer running two containers a month is not looking at a theoretical risk.
How does ISF 10+2 affect small pet product importers?
Three practical realities.
You will not file it yourself. CBP requires the ISF to be transmitted electronically through the Automated Broker Interface (ABI) or the Automated Commercial Environment (ACE). That means a licensed U.S. customs broker or another qualified software vendor. Budget for the service as a fixed line in your landed cost, not as a surprise.
Your supplier controls half your deadline. Manufacturer name and address, country of origin, stuffing location and consolidator all originate overseas. Put the data request into your purchase order so the factory returns it at booking, not a week later. A supplier who cannot produce a factory name and address for ISF purposes is telling you something about traceability.
Small orders are not automatically exempt. Bulk and break-bulk cargo, foreign cargo remaining on board (FROB), immediate exportation (IE) and transportation and exportation (T&E) shipments use a reduced five-element set: booking party, foreign port of unlading, place of delivery, ship to party and commodity HTSUS number. CBP also notes that shipments valued under $2,500 can be filed as a Type 11 (Informal) ISF. Ask your broker which applies rather than assuming — a wrong assumption is still a violation.
If you are consolidating several small pet product lines into one container, the stuffing location and consolidator fields are the ones that break, because an LCL shipment is stuffed at a container freight station by a party you have never met. Confirm both addresses in writing before booking.
How much does an ISF filing cost?
CBP does not set a filing fee. What you pay is a service charge from your broker, forwarder or software provider, and it varies by provider and by how much of the data they have to chase. The most expensive ISF is the one filed twice because the first one was wrong, so the cheapest option is usually the broker who already holds your importer of record number, your HTSUS classifications and your supplier list on file.
When you are comparing sourcing quotes, ask whether ISF filing is included. A supplier quote that excludes it is not cheaper, it is just incomplete.
Consolidation changes the economics of the whole filing. Ordering across a dog range, walking and travel lines and everyday care and hygiene consumables in one container means one ISF, one entry and one freight bill. Testing new lines on a low MOQ first lets you find the winners before you commit to a full container. If you want a landed-cost breakdown that includes ISF, contact our sourcing team.
Does ISF apply to air freight or truck shipments?
No. The importer security filing applies to cargo arriving by vessel. Air, truck and rail shipments are outside its scope, although each mode has its own advance electronic data requirements. If you switch from air to ocean to save on freight, the ISF becomes your responsibility for the first time, and the 24-hour-before-lading clock starts at booking.
Can a freight forwarder file the ISF for me?
A licensed U.S. customs broker or another qualified electronic filer can transmit the ISF on your behalf, and most small importers delegate it. Forwarders often arrange it through a broker. Delegation moves the transmission, not the liability: the ISF Importer remains responsible for accuracy and timeliness, so give your filer complete data early and confirm acceptance in writing.
Is there an ISF exemption for low-value shipments?
Not a general one. Per CBP, shipments valued at less than $2,500 can be filed as a Type 11 (Informal) ISF, and FROB, IE and T&E shipments use a reduced five-element set instead of ten. There is no value threshold below which the filing disappears entirely, so check with your broker rather than assuming a small order is exempt.
How long does an ISF take to file?
Transmission takes minutes. Collecting the data takes days if your supplier is slow. A well-run first filing needs the seller, buyer, importer of record number, consignee number, manufacturer, ship to party, country of origin and HTSUS number at least 72 hours before the estimated load date, with stuffing location and consolidator confirmed before the vessel reaches a U.S. port. Put the request in your purchase order and the timeline stops being a problem.
Sources: U.S. Customs and Border Protection, Import Security Filing (ISF) guidance, help.cbp.gov Article 1868; 19 CFR Part 149, Importer Security Filing (eCFR); Security and Accountability for Every Port Act of 2006.
Ready to stock these ideas? Browse wholesale pet KITs →