What is ISF (Importer Security Filing)?

Importer Security Filing (ISF), also known as “10+2,” is a security measure implemented by U.S. Customs and Border Protection (CBP) requiring importers to provide advance cargo information for shipments arriving in the United States by vessel. The ISF program was established under the SAFE Port Act to enhance cargo security and identify high-risk shipments before they arrive at U.S. ports.

The “10+2” nickname derives from the requirement for importers to submit 10 data elements and carriers to provide an additional 2 data elements. ISF filings must be transmitted electronically to CBP at least 24 hours before cargo is loaded onto a vessel destined for the United States.

Why is ISF Filing Important?

What is the purpose of ISF filing?

The primary purposes of ISF are:

1. Security Enhancement: ISF allows CBP to perform risk assessments on incoming cargo before it reaches U.S. shores, identifying potential security threats. 
2. Supply Chain Visibility: The program increases transparency in international supply chains by documenting all parties involved in the transaction. 
3. Advanced Screening: CBP can use ISF data to target high-risk shipments for examination while facilitating the movement of low-risk cargo. 
4. Compliance Framework: ISF establishes a standardized approach to cargo information reporting for ocean imports. 

What happens if I don’t file ISF?

Failure to comply with ISF requirements can result in:

1. Monetary Penalties: Fines of $5,000 per violation for late, incomplete, or inaccurate filings, with potential increases for repeated violations. 
2. Increased Examinations: Non-compliant shipments face higher rates of physical inspection. 
3. Cargo Holds: CBP may issue “do not load” orders for shipments without proper ISF filing. 
4. Delayed Release: Shipments may be held at the port until all documentation requirements are satisfied. 
5. Increased Import Bond Amounts: Consistent non-compliance may lead to higher customs bond requirements. 

The consequences of non-compliance extend beyond immediate penalties to affect your overall importing profile with CBP, potentially resulting in greater scrutiny of future shipments.

ISF Filing Requirements

What information must be included in an ISF filing?

A complete ISF filing must include the following 10 data elements from the importer:

1. Seller (Owner) Name/Address: The name and address of the party selling the goods. 
2. Buyer (Owner) Name/Address: The name and address of the party purchasing the goods. 
3. Importer of Record Number: The IRS number, EIN, Social Security number, or CBP-assigned number of the entity liable for payment of duties. 
4. Consignee Number: The IRS number, EIN, Social Security number, or CBP-assigned number of the entity to which the goods are consigned. 
5. Manufacturer (Supplier) Name/Address: The name and address of the entity that manufactured or supplied the goods. 
6. Ship-To Party Name/Address: The first deliver-to party scheduled to receive the goods in the U.S. 
7. Country of Origin: The country where the goods were manufactured or produced. 
8. Harmonized Tariff Schedule Number: The 6-digit HTSUS number for the imported goods. 
9. Container Stuffing Location: The name and address of the physical location where the goods were loaded into the container. 
10. Consolidator Name/Address: The name and address of the party who arranged for the stuffing of the container. 

Additionally, ocean carriers must provide these 2 elements:

1. Vessel Stow Plan: Information about cargo locations on the vessel. 
2. Container Status Messages: Reports on container movements and status changes. 

When must ISF be filed?

ISF must be filed within specific timeframes:

• Standard Rule: At least 24 hours before cargo is loaded onto a vessel destined for the United States. 
• Flexible Filing Option: For “to order” shipments or those with unknown elements, ISF may be submitted with the best available information, with updates provided as soon as more precise information becomes available. 
• Bulk Cargo Exception: For bulk cargo, ISF must be filed 24 hours prior to vessel arrival rather than prior to loading. 
• Foreign Remaining on Board (FROB) Cargo: For cargo that will remain on the vessel, ISF must be filed 24 hours prior to vessel arrival at the first U.S. port. 

What are the different types of ISF filings?

There are several types of ISF filings based on the nature of the shipment:

1. ISF-10: The standard filing for most imports, requiring all 10 data elements. 
2. ISF-5: A simplified filing for cargo that will not be entering U.S. commerce, including: 
   • Foreign Cargo Remaining on Board (FROB)
   • Immediate Exportation (IE)
   • Transportation and Exportation (T&E)
   • Immediate Transportation (IT)
3. Unified ISF: For shipments consisting of both ISF-10 and ISF-5 cargo types. 
4. Amended ISF: Filed when changes occur to previously submitted information. 

How ISF Relates to AMS and SCAC Codes

How do ISF, AMS, and SCAC codes work together in the import process?

ISF, AMS, and SCAC codes are interconnected components of the U.S. import compliance framework:

1. ISF focuses on advanced security information about the cargo and transaction parties, provided by the importer. 
2. AMS (Automated Manifest System) deals with cargo manifest information, typically submitted by carriers. 
3. SCAC (Standard Carrier Alpha Code) serves as the unique identifier for carriers in both ISF and AMS filings. 

In practice, these systems form a comprehensive supply chain visibility framework:

• SCAC codes are required in both ISF and AMS filings to identify carriers
• AMS filings include the carrier’s cargo declaration information
• ISF filings include details about the transaction and supply chain participants

All three elements must align for smooth customs clearance. For example, the carrier identified by a specific SCAC code in your ISF filing must match the carrier submitting the AMS information for the same shipment.

What is the difference between ISF and AMS filing?

While ISF and AMS both involve advance electronic filings for imports, they differ in several key ways:

Despite these differences, both systems work together to facilitate secure and efficient imports, with information between them often cross-referenced by CBP.

ISF Filing Process

Who is responsible for filing ISF?

The responsibility for ISF filing falls primarily on:

1. The Importer of Record: Ultimately responsible for ensuring ISF compliance. 
2. Authorized Agents: May file on behalf of the importer, including: 
   • Customs brokers
   • Freight forwarders
   • Non-vessel operating common carriers (NVOCCs)

While importers can authorize third parties to file on their behalf, the legal responsibility remains with the importer. This means penalties for non-compliance are typically issued to the importer, even if the filing was delegated to an agent.

How do I file an ISF?

ISF can be filed through several methods:

1. ABI (Automated Broker Interface): Most customs brokers use this system to submit ISF filings. 
2. Vessel AMS: Some carriers and service providers use this system. 
3. Service Providers: Third-party filing services offer ISF solutions. 

The filing process typically includes:

1. Gathering Required Information: Collecting all 10 data elements from various supply chain participants. 
2. Data Validation: Verifying accuracy of all information prior to submission. 
3. Electronic Submission: Transmitting the data to CBP through approved channels. 
4. Receiving Confirmation: Obtaining an ISF filing confirmation number. 
5. Tracking Status: Monitoring the status of the filing and addressing any issues identified by CBP. 

For most importers, working with a qualified customs broker or freight forwarder is the most efficient approach to ISF compliance.

How do I comply with ISF Filing if I don’t have a US Importer?

If you’re shipping goods to the United States without having an established US importer entity, you still need to meet ISF requirements. This scenario is common for companies that ship directly to fulfillment warehouses like Amazon or third-party warehouses under Fulfillment by Amazon or Fulfillment by Merchant.

In these situations, you have two primary options:

1. Importer of Record (IOR) Service: A third-party service provider acts as the importer of record for your shipments, taking legal responsibility for the import transaction. 
2. Foreign Importer of Record (FIOR): Your own foreign entity can serve as the importer of record, allowing you to maintain more control over the import process. 

Both options enable you to fulfill ISF requirements while shipping to the US market without establishing a US entity.

What is a Foreign Importer of Record and what are its benefits?

Foreign Importer of Record (FIOR) is an arrangement that allows a non-US entity to act as the importer of record for shipments entering the United States. This option provides several key benefits:

1. Use Your Own Entity to Import: You can maintain direct control over the import process without establishing a US subsidiary. 
2. No Reliance on Third-Party Importers: Avoid dependency on US-based partners or service providers for import transactions. 
3. Fixed Yearly Fee Structure: Rather than paying percentage-based fees typically charged by Importer of Record services (often 1-5% of shipment value), FIOR arrangements usually involve a fixed annual fee. 
4. Streamlined Supply Chain: Simplify operations by eliminating an intermediary from your import process. 
5. Consistent Import History: Build a direct compliance record with US Customs under your own company name. 

To establish a Foreign Importer of Record arrangement, you’ll need to:

• Obtain a US Customs Bond
• Secure a Continuous Import Bond
• Register for a Customs Assigned Number
• Set up proper ISF filing processes

At GOL Solution, we offer comprehensive Foreign Importer of Record setup services that can be completed in just 3-5 business days. Our expedited process handles all registration requirements, documentation, and system setups to get your FIOR arrangement operational quickly and efficiently.

Can I authorize ISF Filing to my freight forwarder or customs broker?

Yes, you can authorize your freight forwarder or customs broker to handle ISF filings on your behalf. This is a common practice that offers several advantages:

1. Expertise: These professionals typically have extensive experience with ISF requirements and CBP systems. 
2. Efficiency: They often have established processes and direct connections to filing systems. 
3. Integration: They can coordinate ISF with other import documentation, including AMS filings. 
4. Reduced Risk: Their expertise helps minimize errors that could lead to penalties. 

To properly authorize a third party for ISF filing:

1. Provide Written Authorization: Execute a power of attorney or authorization letter. 
2. Share Required Information: Ensure they have access to all necessary data elements. 
3. Establish Communication Protocols: Set clear expectations for updates and issue resolution. 
4. Verify Responsibility: Understand that while they perform the filing, you remain legally responsible for compliance. 

Even when delegating the filing task, importers should maintain oversight of the process and ensure all information provided is accurate and complete.

Common ISF Challenges and Solutions

What are the most common ISF filing errors?

The most frequent ISF filing errors include:

1. Late Filings: Submitting after the 24-hour deadline, often due to last-minute shipments or communication delays.
   
   Solution: Implement standardized procedures requiring ISF information collection earlier in the shipping process. 
2. Incomplete Information: Missing one or more of the required 10 data elements.
   
   Solution: Use comprehensive checklists and automated validation systems to ensure all fields are completed. 
3. Inaccurate Harmonized Tariff Schedule (HTS) Classifications: Providing incorrect 6-digit HTS codes.
   
   Solution: Invest in proper product classification by qualified professionals or utilize classification databases. 
4. Wrong Manufacturer Information: Listing trading companies or intermediaries instead of actual manufacturers.
   
   Solution: Implement supplier verification processes and maintain updated manufacturer databases. 
5. Incorrect Bill of Lading Numbers: Discrepancies between ISF and actual carrier documentation.
   
   Solution: Coordinate closely with carriers and verify bill of lading information before ISF submission. 
6. Missing Updates for Changed Information: Failing to amend ISF when shipment details change.
   
   Solution: Establish clear communication channels with all supply chain partners and implement change notification protocols. 

How can I reduce ISF compliance risks?

To minimize risks associated with ISF compliance:

1. Develop Written Procedures: Create documented processes for gathering and validating ISF information. 
2. Establish Information Collection Timelines: Implement schedules that ensure all data is available well before the 24-hour deadline. 
3. Train Supply Chain Partners: Educate vendors, suppliers, and internal teams about ISF requirements and their roles. 
4. Utilize Technology Solutions: Implement systems that automate data collection, validation, and submission processes. 
5. Conduct Regular Compliance Reviews: Periodically audit ISF filings to identify patterns of errors or areas for improvement. 
6. Maintain Updated Information: Ensure manufacturer, supplier, and other key databases are current and accurate. 
7. Work with Experienced Service Providers: Partner with customs brokers or freight forwarders with proven ISF expertise. 
8. Monitor CBP Updates: Stay informed about regulatory changes and enforcement priorities related to ISF. 

By implementing these strategies, importers can significantly reduce the risk of ISF penalties and shipment delays.

ISF Best Practices

What are the industry best practices for ISF compliance?

Leading importers follow these ISF best practices to ensure consistent compliance:

1. File Early: Submit ISF 48-72 hours before vessel loading when possible, rather than waiting until the 24-hour deadline, to allow time for corrections if needed. 
2. Standardize Vendor Requirements: Incorporate ISF data requirements into supplier agreements and purchase orders. 
3. Implement Automated Data Exchange: Develop systems for electronic information sharing between supply chain partners. 
4. Utilize Single Entry Process: Combine ISF with customs entry filing when possible to reduce redundancy and potential discrepancies. 
5. Establish Clear Communication Protocols: Define responsibilities and information flow between all parties involved in the import process. 
6. Monitor Filing Status and Confirmations: Track ISF submissions through electronic acknowledgments and take immediate action on any issues. 
7. Conduct Regular Training: Ensure all team members involved in the import process understand ISF requirements and procedures. 
8. Perform Post-Entry Analysis: Review filing history to identify trends, common errors, or areas for improvement. 
9. Integrate with Related Compliance Programs: Align ISF processes with Customs-Trade Partnership Against Terrorism (C-TPAT) and other security initiatives. 
10. Document Reasonable Care Efforts: Maintain records of compliance measures to demonstrate due diligence if questions arise. 

How can I stay updated on ISF regulations and requirements?

To remain current on ISF regulations and requirements:

1. Subscribe to CBP Communications: 
   • CSMS (Customs and Border Protection Messaging Service)
   • ACE Outreach newsletters
   • CBP bulletins and publications
2. Join Industry Associations: 
   • NCBFAA (National Customs Brokers & Forwarders Association of America)
   • AAEI (American Association of Exporters and Importers)
   • Local trade organizations
3. Attend CBP Outreach Events: 
   • Trade symposiums
   • Webinars
   • Regional trade conferences
4. Follow Trade Publications: 
   • Journal of Commerce
   • American Shipper
   • Inbound Logistics
5. Establish Relationships with CBP Personnel: 
   • Centers of Excellence and Expertise (CEE)
   • Client Representatives
   • Port contacts
6. Consult Regularly with Service Providers: 
   • Customs brokers
   • Trade attorneys
   • Compliance consultants
7. Participate in Automated Systems Programs: 
   • ACE Portal account
   • Electronic outreach initiatives

Staying informed about regulatory changes and enforcement priorities is essential for maintaining effective ISF compliance strategies.

Expert ISF Filing Services for Seamless Imports

At GOL Solution, we specialize in providing comprehensive ISF filing services to ensure your ocean shipments enter the United States without costly delays or compliance issues.

Our ISF Expertise

With extensive experience in international trade compliance, we offer:

• Complete ISF Filing Solutions for all types of ocean imports
• Integration with AMS and Customs Entry processes
• Expert Handling of standard and complex filing scenarios
• SCAC Code Management and validation services
• Real-time Filing Status Monitoring

Solutions for Importers Without US Entities

We provide specialized solutions for businesses shipping to the US without established importer entities:

• Foreign Importer of Record (FIOR) Setup completed in just 3-5 business days
• Fixed Fee Structures that eliminate percentage-based costs
• Complete ISF Compliance Management for all customs requirements

Our expedited FIOR setup service handles all registration requirements, customs bond arrangements, and system access to get you importing under your own entity quickly and with minimal hassle.

Our ISF Filing Process

Working with GOL Solution for your ISF needs is simple and efficient:

1. Provide Basic Shipment Information: 
   • Commercial invoice
   • Packing list
   • Bill of lading
   • Purchase order details
2. We Handle the Details: 
   • Data validation and formatting
   • Electronic submission to CBP
   • Confirmation tracking
3. Receive Regular Updates: 
   • Filing confirmation
   • Status notifications
   • Resolution of any CBP questions

Why Choose Our ISF Services?

1. Proven Expertise: Our team has successfully managed thousands of ISF filings for importers across diverse industries
2. Comprehensive Approach: We coordinate ISF with related requirements including AMS and customs entry
3. Risk Reduction: Our rigorous validation processes minimize the chance of penalties or delays
4. Cost-Effective Solutions: Avoid the expense and complexity of building in-house filing capabilities
5. Peace of Mind: Focus on your core business while we handle your compliance requirements

Ready to Streamline Your ISF Compliance?

Contact us today to learn how our ISF filing services can help you navigate the complexities of US Customs requirements with confidence and efficiency. Our team is ready to support your international shipping needs with expert guidance and reliable filing services.