ISF 10+2 is the operational name for Importer Security Filing, reflecting its two-party data split: 10 elements from the importer of record and 2 from the ocean carrier. The rule is codified at 19 CFR Part 149.
The 10 importer elements must be filed no later than 24 hours before the cargo is laden onto the vessel at the foreign port:
- Seller (owner of the goods at time of sale)
- Buyer (owner at time of purchase)
- Importer of record number (IRS/EIN/SSN/CBP-assigned)
- Consignee number
- Manufacturer (or supplier)
- Ship-to party (first delivery address in U.S.)
- Country of origin
- Commodity HTSUS number (6-digit minimum)
- Container stuffing location
- Consolidator (stuffer)
The 2 carrier elements:
- Vessel stow plan — submitted no later than 48 hours after vessel departure from last foreign port
- Container status messages (CSM) — submitted within 24 hours of each CSM event
ISF became effective January 26, 2009, with a 12-month phase-in. Full enforcement (liquidated damages) began July 9, 2013. The maximum penalty is $5,000 per ISF violation with a $10,000 per-shipment cap. Common violations include late filing, no filing, and inaccurate data.
Elements 5, 6, 7, and 10 can be updated as late as 24 hours before vessel arrival at the U.S. port — recognizing that some data isn't final at the time of lading (especially for LCL consolidations).
A common compliance pattern is for the customs broker to also handle ISF filing, since they already have the importer's data and ABI connectivity.