ISF, the 10+2 rule, requires the importer to file 10 data elements with CBP before ocean cargo is loaded at the foreign port, and the carrier to file 2 more. Eight of the importer's elements are due 24 hours before loading. Miss the deadline or file bad data and CBP can assess $5,000 in liquidated damages per violation.
The ten elements, and who files what
The name 10+2 is literal. The importer files 10 data elements about the shipment: seller, buyer, importer of record, consignee, manufacturer, ship-to party, country of origin, HTS number, container stuffing location, and consolidator. The ocean carrier files 2: the vessel stow plan and the container status messages. The importer owns the 10, the carrier owns the 2, and the importer of record holds the liability for the whole filing even when a broker or forwarder transmits it.
The rule comes from the SAFE Port Act of 2006 and lives in 19 CFR Part 149. It covers nearly all non-bulk ocean cargo arriving in the United States, including containerized shipments, break-bulk cargo, and roll-on roll-off vehicles. Air freight, trucked goods from Canada or Mexico, and bulk commodities like grain are exempt. If the cargo moves by ocean, the filing is due, and the importer of record is the one CBP holds responsible.
Related reading on this site: LandedWatch and LandedWatch cover the neighbouring problems in more depth.
Two deadlines, not one
The deadline most importers miss is the split. Eight of the ten importer elements are due at least 24 hours before the cargo is loaded onto the vessel at the foreign port. The deadline is tied to loading, not to the vessel's departure time, and that distinction has caught more than one importer who filed against the sailing schedule. The other two elements, container stuffing location and consolidator, are due no later than 24 hours before the vessel arrives at a US port.
The practical move is an internal cutoff of 48 to 72 hours before loading, which leaves a full day of buffer beyond CBP's 24-hour legal minimum. The data has to come from the supplier, the forwarder, and the consolidator, and none of them move fast when asked at the last minute. A filing built on guessed data is worse than a late filing, because an inaccurate filing draws the same $5,000 penalty and the correction draws another one.
What a $5,000 violation actually looks like
CBP's standard liquidated damages claim for a late, inaccurate, or missing ISF filing is $5,000 per violation. Multiple errors on one shipment can stack into separate claims against the bond: a late filing plus an inaccurate HTS number is two violations, not one, and the total can reach $10,000 on a single shipment. A late or wrong filing can also trigger a hold or an exam at the port of arrival, which is where the demurrage clock starts running on top of the penalty.
The mitigation path exists but it is narrow. CBP's own guidelines allow a first violation to be reduced to between $1,000 and $2,000 when law enforcement goals were not compromised. That is a mitigation petition, not a right, and it works best when the importer can show a process that failed once, not a process that never existed. The cheapest ISF program is the boring one: a checklist, a cutoff, and a named person who owns the filing for every ocean shipment.
Frequently asked questions
What is ISF 10+2?
The Importer Security Filing is a CBP rule for ocean cargo. The importer files 10 data elements about the shipment and the carrier files 2, the vessel stow plan and container status messages. It applies to nearly all non-bulk ocean cargo entering the United States.
When is the ISF due?
Eight of the ten importer elements are due at least 24 hours before the cargo is loaded onto the vessel at the foreign port. The other two, container stuffing location and consolidator, are due no later than 24 hours before the vessel arrives at a US port.
What happens if I file ISF late?
CBP can assess $5,000 in liquidated damages per violation, and multiple errors on one shipment can stack into separate claims. A late filing can also trigger a hold or an exam at the port of arrival. First violations can be mitigated to $1,000 to $2,000 when law enforcement goals were not compromised.
Does ISF apply to air freight?
No. ISF covers ocean cargo only. Air freight, trucked goods from Canada or Mexico, and bulk commodities like grain are exempt from the rule.