|What is ISF?
Importer Security Filing (ISF) is a U.S. Customs and Border Protection (CBP) regulation that affects reporting requirements for
ocean shipments entering the United States, or shipments that transit the United States to a foreign destination. Commonly
referred to as "10+2" for the number of the data elements required, ISF regulations require importers and Vessel Operating
Carriers to submit specific information pertaining to ocean cargo in advance of entering the country. The targeted cargo screening
initiative was developed to help prevent high-risk shipments from being transported to the United States and is fully enforced by
With 10+2, the importer is ultimately responsible for the filing. It is imperative that the ten ISF data elements are completed timely
and accurately in order to fully comply with the regulations. The Vessel Operating Carrier is responsible for an additional two
elements, which are the vessel stow plan and container status messages.
ISF-5 is a separate and distinct data reporting requirement for shipments that are transiting the United States but not remaining in
the country, and requires the importer to file five data elements.
What does it mean to me?
ISF-10 ("10+2") regulations require advance transmission of trade data 24 hours prior to vessel lading for containerized freight, and
24 hours prior to arrival at the port of discharge for break bulk shipments. (Importers of bulk cargo are exempt from filing an ISF with
respect to that cargo.)
All ISF filings are to be done electronically via vessel Automated Manifest System (AMS) or the Automated Broker Interface (ABI).
Corrections and updates must be made before the goods enter the limits of a U.S. port. Only the party who submitted the original
filing may make changes.
ISF-5 applies to foreign cargo remaining on board. Foreign Remaining On Board (FROB) filings are required for freight on board a
vessel that will dock in the United States before moving to foreign port of destination or freight that will move in-bond through the
United States to a foreign destination. This type of ISF filing requires five data elements and must be filed by the ISF importer prior
to lading. For the purposes of the FROB filing, the importer of record is construed to be the carrier.
Per CBP, failure to comply with these regulations will result in amendments to the importers bond conditions, including the issuing
of liquidated damages up to $5,000 USD per violation, with a maximum of $10,000 USD per shipment. CBP can assess these
damages on late or inaccurate ISF filings & etc.
What Can You Do?
Be proactive. Check with your customs broker or ISF filer if you do not file on your own. Make sure you understand where you are
having existing issues with late or inaccurate filings and what you can do to correct them.
Additionally, monitor your ISF filings through your ACE portal. If you do not have one you can obtain an application from the CBP
website at Home >> Trade >> Automated and Operational Systems/ACE: Modernization Information Systems or for questions, write
to ACE.Support@cbp.dhs.gov; the service is free to all importers.
You should also monitor the status codes provided by CBP for your shipments. Remember that along with the "10+2" data
elements, both the importer and carrier must supply a bill of lading number. This is the number CBP is using to match the importer
ISF and carrier AMS filings and to determine timeliness of filings. CBP considers unmatched files as a non-filing. The status codes
are as follows:
For Customs Broker / ABI Filer (ISF Status Codes (Disposition Codes by cbp or Search)
S1: AMS bill and ISF match
S2: AMS bill and ISF do not match at time of filing
S3: AMS bill and ISF do not match 5 days after ISF is accepted
S4: AMS bill and ISF do not match 20 days after ISF is accepted
S5: AMS bill and ISF do not match 30 days after ISF is accepted
S6: No bill match (wrong type)
S7: Duplicate ISF by another filer
SA: AMS bill match (wrong type) 5 days after filing the ISF
SB: AMS bill match (wrong type) 20 days after filing the ISF
SC: AMS bill match (wrong type) 30 days after filing the ISF
(For Carriers / Vessel company, ONLY)
2O - ISF Hold for no ISF on file
2P - ISF Hold for ISF Compliance Issue
2Q - Do Not Load – No ISF on file
2R - Do Not Load – ISF Compliance Issue
4O - ISF Hold Removed for no ISF on file
4P - ISF Hold Removed for ISF Compliance Issue
4Q - Do Not Load Removed for no ISF on file
4R - Do Not Load Removed for ISF Compliance Issue
Pay particular attention to any S3 status. Check with your carrier to determine if you have submitted the correct bill of lading number.
It is possible the carrier may not have submitted the bill of lading number to AMS but it is in your best interest to find out. By the time
a filing reaches S4 or S5 it may be too late to make any changes and CBP could consider this a non-filing.
CBP remains vague as to what constitutes an inaccurate filing. Filers are required to "submit information on the basis of what it
reasonably believes to be true." The original ruling allowed for amendments to be made before vessel arrival if more accurate
information became available; for example, a change in the bill of lading number or a conflict between house and master bills. At
this point it is not known if an amended filing will be considered to have been inaccurate and therefore trigger a fine. Check with
your broker or filer for clarification on this point as more information from CBP becomes available.
As far as can be determined, all fines and penalties will be reviewed by Washington before claims for liquidated damages are
assessed. First violations could be reduced to between $1,000 and $2,000 depending on mitigating or aggravating factors.
Subsequent violations could be reduced to $2,500 provided CBP determines that law enforcement goals were not compromised by
the violation. No relief will be granted if CBP determines that law enforcement goals were compromised by the violation. We
reasonably believe the fine will be capped at $10,000 per ISF.
More information can be obtained by reviewing the FAQ's on the CBP website at Home >> Trade >> Cargo Security.
How Serious Is CBP?
While we can be confident that CBP will enforce this ruling, full enforcement could potentially be a serious impediment to the
importing community and carriers. Looking at some hypothetical numbers, in 2012, CBP processed approximately 30 million
entries. Let's assume only 10% of these are subject to ISF filing. Let's further assume only 1% of these would be subject to
liquidated damages for ISF violations. That's 30,000 entries at $5,000 dollars each, meaning CBP stands to collect $150 million
dollars in the next year.
How Serious Are You?
How many ISF filings does your company make each year? Assume 1% of that number and multiply by $5,000. Can you afford to
add that amount to your cost of doing business? Obviously not. Therefore you need to be as proactive as possible between to
ensure you are doing all you can to make sure your ISF filings are timely and accurate.
Search (no bill match not on file)
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|1. ISF 10+2 (Importer Security Filing) / ISF FAQ. 63 pages / (click here)
2. US Local Ports Contact / e-Allegations / Anonymous tips (8663472423)
3. Air Forwarders by Air Forwarders Association / iata.org.
4. Ocean Freight Forwarder: Federal Maritime Commission (FMC)
5. Filing a Complaint Freight Forwarder/NVOCC/ etc with FMC.gov.
6. US Government Agencies / www.usa.gov.
7. For more links to import, export & etc. Industry.
8. Basic Importing by CBP.gov (Import requirements 211 pages) & for others.
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