Importer Security Filing (ISF): Everything You Need to Know

ISF is a term frequently heard among the importer community in the US. It is a critical part of the customs clearance procedure that ensures seamless entry of ocean cargo inside the United States borders.

Importer Security Filing can become an overwhelming task despite seeming a process requiring the submission of a few pieces of information from here and there. However, it is a matter of informational accuracy, following timing, and supply chain transparency. To help with all the answers you need, we are going to break down the details of ISF filing in this article. Let’s read.

What Does ISF Mean?

ISF meaning Importer Security Filing is an important procedure required for ocean cargo being imported into the United States. It is also referred to as “10+2” and mandated by the Customs and Border Protection (CBP), US.

Importer Security Filing is a process that ensures the collection of all information and details related to the entire importing journey of any shipment. It is crucial for the ISF to be submitted to the CBP minimum of 24 hours prior to the concerned shipment starting for its import to the US.

Note: ISF is only applicable to the vessel or ocean cargo and not break-bulk cargo or air freight.

ISF rule came up as a part of the Trade Act of 2002 and SAFE Port Act of 2006 but came into effect in 2009.

Read: A Complete Guide for Importing into the US

Why Importer Security Filing Is Important?

As per the data generated from Trademo Intel for the year 2021, an average of imports worth $8.04 Billion entered US borders in a single day. The information submitted to CBP through ISF helps it filter out high-risk shipments from such a massive number of imports, prevent illegal trading activities, and ensure cargo safety.

It is to remember that ISF doesn’t decide the entry of any cargo into the US but only ensures verification and assessment of the documents and risk involved (if any).

What Information Is Required for ISF Filing?

The “10+2” mentioned above actually denotes the number of information elements required while filling out an ISF form. The concerned information is a must-have for importer security filing and needs to be submitted according to the timeline.

Here are the first 10 documents that need to be submitted by the importer:

24 hours before the goods are loaded onto the vessel:

1. Name and address of the supplier/manufacturer
2. Name and address of the owner/seller
3. Name and address of the buyer
4. Name and address of the ship-to party
5. Commodity Harmonized Tariff Schedule Number (HTS) number of every good in the shipment (minimum of 6 digits)
6. Country of Origin
7. Importer of record number/foreign trade zone applicant identification number
8. Consignee number

24 hours before the arrival of the goods:

9. Name and address of the Consolidator/stuffer
10. Container stuffing location

Here are the +2 documents that need to be submitted by the carrier:

1. Container status message data (CSM)
2. Vessel stow plan (48 hours before the departure of the shipment)

What Is ISF-5?

The 10+2 rule is not essential for all shipments as there are some exceptions. Such shipments are called FROB or Freight Remaining on Board, T&Es or Transportation & Exportations, or IEs or Immediate Exportations.

For the ISF-5 filings, the following information is required:

1. Name and address of the ship-to party
2. Name and address of the booking party
3. Commodity HTS number (minimum 6 digits)
4. Foreign port of unlading
5. Location of delivery

Who Is Responsible for Submitting ISF?

The ultimate responsibility of ensuring proper ISF submission lies with the ISF Importer. This is because the importer is initiating the transfer of goods within the limits of a port in the USA by vessel. The ISF importer is commonly considered the purchaser, owner, or consignee of the goods, and even an agent like a licensed customs broker.

You can even get a licensed customs broker or an in-house broker (if you have one) to file the ISF. Importers can also self-submit the ISF form online if they have an account and access to the ACE portal of CBP.

What Is the Procedure for Filing ISF?

As per the US CBP, ISF information filing is mandatory for security purposes of containerized shipments. The IOR must check the data elements submitted as required under ISF 10+2 and ISF 5.

Following are the steps to follow while submitting ISF online:

1. Make sure to have all the required information collected well in advance to be adherent to the timeline of submission. All the information elements mentioned above must be ready for submission at least 24 hours prior to lading.
2. The data has to be submitted on an online portal of the CBP called Automated Broker Interface in the Automated Commercial Environment (ACE) portal. The IOR can self-file or through a CBP-licensed service provider. You can use the portal to manually edit and cross-check the information and view ISF status/CBP logs to track the submission.

Note: If you want to save filing fees, gain enhanced visibility of the supply chain, and ensure successful compliance, it is advisable for you to self-file ISF as the IOR.

3. After duly submitting the ISF, it is crucial to track the status of the filing.

Are There Any Precautions to Take While Filing ISF?

There are a few best practices and precautions one can follow while filing ISF:

• It is advisable to not delay the filing until the last minute. A 72-hour window would give enough time for smooth submission and processing of the information.
• Make sure to amend the ISF filing if any information changes or gets updated before the time of arrival in the US.
• Ensure that the bill of lading number matches the one submitted in the CBP at least 24 hours before cargo arrival. It is critical to report the correct bill of lading number for attaching the ISF to the manifest data and entry.
• If you wish to take over ISF filing from a third-party broker midway, you must get the initial filing canceled by contacting the CBP representative and restart filing by yourself.
• Open a communication channel with your vendors. Hold them responsible for providing accurate information regarding the ISF filing and ensuring trade compliance.
• Review and monitor monthly progress reports of the ISF filings to assess the error and on-time percentage.

Is There Any Fee for Filing ISF?

Generally, custom brokers charge a small fee of $30 to $50 for filing ISF. Most of them also combine this fee with the ISF bond which leads to the total fee ranging between $80-$120. This fee is a better bet as compared to the hefty penalties incurred upon non-compliance. As the brokers make sure that all the required information for the ISF 10+2 reporting is gathered timely, the fee is valid for their efforts.

What Are the Consequences of ISF Non-Compliance?

CBP has set guidelines on the consequences of failure to comply with the ISF rules and procedures. This includes huge penalties, interrupting inspections, and shipment delays.

As per the guidelines, CBP can:

• Impose liquidated penalties of $5000 per violation including inaccurate, incomplete, or late filing
• Withhold release or transfer of goods for which an ISF has not been filed
• Refuse permit for unlading of non-compliant goods
• Seize any goods that have been non-compliant yet unladen without the permission
• Subject non-compliant goods to ‘do not load’ order at origin or get them inspected upon arrival

Conclusion

As customers expect faster deliveries, delayed or withheld shipments are not an option for importers. While it is difficult to be completely ready for the unexpected supply chain challenges, the best US importers can do is ensure full compliance with the CBP requirements like ISF filing. This can also help importers gain better visibility through their supply chain and establish better relations with the vendors for smooth and trustful trade. Trademo Compliance can help you leverage the latest global trade compliance content to know all the import/export norms you need to meet for your goods.

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