ISF — Importer Security Filing, universally called the 10+2 rule — is a US Customs and Border Protection requirement that cargo data be transmitted before ocean cargo is loaded onto a vessel bound for the United States. The legal duty sits with the importer of record in the USA, but almost every data element originates with the Indian exporter, and a late or wrong ISF is exactly what stops a container from being loaded. This guide sets out the ten importer elements and two carrier elements, the deadlines, who may file, the narrow exemptions, what a failure costs, and the documentation habits that keep US-bound cargo moving.
What ISF is and why CBP requires it
ISF is a pre-arrival security declaration codified at 19 CFR Part 149. CBP uses the data to risk-assess cargo while it is still on the water, so a high-risk container can be examined, held or refused before it reaches a US port rather than after. It is called 10+2 because the importer of record must transmit ten data elements and the vessel operating carrier must transmit two more. Filing is electronic, through the Automated Commercial Environment (ACE) via a customs broker or filing service, or through CBP's own ISF portal.
When ISF must be filed
| Situation | ISF deadline |
|---|---|
| Container loaded at a foreign port for direct sailing to the USA | No later than 24 hours before the container is laden on board the ocean vessel |
| Cargo transshipped through a hub such as Colombo, Jebel Ali or Singapore | 24 hours before lading on the vessel departing the last foreign port for the USA |
| Cargo short-shipped or rolled to a later vessel | Amend the existing ISF before the container is laden on the new vessel; a fresh ISF is needed if the shipment was never declared |
| In-bond cargo moving inland in the USA | ISF filed before lading, with the remaining elements due at least 24 hours before arrival at the first US port |
| Cargo sold on the high seas after sailing | The new importer of record must file before arrival and the earlier filing must be amended |
The practical consequence is timing on the export side: the data has to reach the US importer or broker several days before the carrier's cutoff, not after the bill of lading is released. Exporters who send final invoice and packing details only at sailing routinely cause late filings they are then blamed for.
The ten data elements the importer must provide
| # | Data element | Who normally supplies it | Watch-outs |
|---|---|---|---|
| 1 | Supplier — entity selling the goods | Indian shipper or factory | The actual supplier, never the forwarder |
| 2 | Purchaser — buyer of the goods | US buyer | A trading company is not automatically the purchaser |
| 3 | Ship-to — first deliver-to in the USA | US buyer | A real US address; 'in transit' is rejected |
| 4 | Manufacturer — entity that makes the goods | Indian factory | Different from the supplier when a trader exports |
| 5 | Manufacturer ID — government-issued identifier | Indian factory | Use the same DUNS or equivalent on every shipment |
| 6 | HTSUS number — at least 6 digits | Exporter and broker | A wrong heading means wrong duty and targeting risk |
| 7 | Container stuffing location | Exporter or CFS | Where stuffing physically happened, not the office address |
| 8 | Consolidator — party that consolidated the load | CFS or consolidator | For a factory-stuffed FCL, the factory is the consolidator |
| 9 | Buyer — party in the transaction that includes the importation | US buyer | Can differ from the consignee on a switch bill |
| 10 | Importer of record number and customs bond | US importer or broker | A foreign IOR needs a US agent and a bond |
Six of the ten come straight from the factory or the shipping bill: supplier, manufacturer, manufacturer ID, HS heading, stuffing location and consolidator. That is why an exporter who keeps a verified data sheet on file can support any US buyer without hunting for answers at cutoff.
The two carrier elements
- Master bill of lading number — the carrier's own MBL, transmitted by the vessel operating carrier or by an NVOCC acting as carrier of record.
- Vessel stow plan — the container's location on board, transmitted by the carrier, which also shows where dangerous goods and reefer units sit.
Where cargo moves on a house bill, the NVOCC is the carrier of record for the master-level elements while the importer remains responsible for the ten. A house bill number is not a substitute for the master bill number in the carrier's filing, and mixing the two is a common source of mismatched records.
Who may file, and how
- 1The importer of record can file directly on CBP's ISF portal, though most importers use a licensed US customs broker or filing service connected to ACE.
- 2A broker or agent files under a power of attorney from the importer; responsibility for accuracy still rests with the importer of record.
- 3The freight forwarder or NVOCC normally gathers the ten elements from the Indian exporter and passes them to the importer's broker — a service role, not a transfer of liability.
- 4Importers with regular flows hold a continuous bond so repeated entries run on one bond; a single-transaction bond covers one entry only.
- 5Any change to the data must be filed as an amendment immediately — before lading where possible, and without delay afterwards.
Exemptions and cargo outside the rule
- ISF applies to ocean cargo only — air freight, courier and land movements are not subject to it.
- Cargo in transit through the USA under certain in-transit provisions, government and military cargo, and vessel supplies are exempt.
- Baggage, personal effects and some temporary importation movements are exempt or partly exempt, and the exemption must be claimed correctly rather than assumed.
- Destinations inside the US customs territory, including Puerto Rico and Guam, are generally in scope — do not assume they are outside the rule.
Exemptions are narrow and documentation-driven. Where a shipment is to be treated as exempt, the US broker should confirm the exact regulatory provision being relied on before the vessel cutoff, in writing.
What a failure costs
- Do Not Load or Do Not Stow instructions: carriers can refuse to load a container whose ISF is not filed or not accepted, rolling it to the next sailing.
- Arrival holds and exams: late or inaccurate filings raise the chance of a container or CET exam at the US port, with demurrage and detention running throughout.
- Liquidated damages: CBP can assess up to $5,000 per violation for failure to file, late filing or inaccurate filing, with each breach treated separately.
- Mitigation is available where no CBP enforcement interest was harmed, but it has to be applied for and it does not repair a lost sailing.
- Repeat failures damage the importer's compliance profile, which affects bond sufficiency and how future shipments are targeted.
For exporters the real damage is commercial rather than legal: a container left behind because the buyer's broker did not have the data in time is a missed sailing, a reefer plugged in at origin for nothing, and a buyer who starts looking at another supplier.
A practical ISF workflow for Indian exporters
- 1Build a one-page ISF data sheet before production finishes: supplier, purchaser, ship-to, manufacturer and its ID, HS heading, stuffing location, consolidator, buyer and importer of record details.
- 2Send the draft data sheet to the US buyer's broker at least five days before the vessel cutoff, not with the final document set.
- 3Confirm in writing who the importer of record is and that a power of attorney and customs bond are already in place.
- 4Agree who amends the filing when quantity, weight, HS code or consignee changes, and within what time.
- 5Keep the master and house bill numbers, vessel and ETD, container and seal numbers with the data sheet so the broker can match the filing to the physical cargo.
- 6Archive the filing confirmation with the shipping bill and bill of lading copy for five years.
The DAP and DDP trap
Under FOB, CFR, CIF or DAP the US buyer is the importer of record and files the ISF, but the exporter still has to hand over accurate data early enough for the deadline to be met. Under DDP the Indian seller has taken on the import side as well: somebody must act as US importer of record, hold a customs bond and file the ISF, and a non-resident seller normally cannot do that without a US entity or a registered agent. Quoting DDP into the USA without a US-side arrangement already in place is the quickest route to a stranded container.
Frequently asked questions
Is ISF required for air shipments to the USA?
No. ISF applies to cargo arriving by ocean vessel. Air cargo is subject to other advance-information requirements, but not the 10+2 ISF filing.
Who is responsible for ISF — the Indian exporter or the US buyer?
The importer of record in the USA is legally responsible for filing ISF and for the accuracy of the data. The Indian exporter is normally the source of six or more of the ten elements, and a forwarder may file as agent under a power of attorney, but liability stays with the importer of record.
What is the ISF deadline?
As a rule, no later than 24 hours before the container is laden on board the ocean vessel at the last foreign port from which it will travel to the USA. In-bond and short-shipped cargo carry additional reporting steps, so complete data should be with the broker well before that point.
What happens if ISF is filed late or with wrong data?
CBP can assess liquidated damages of up to $5,000 per violation, and the container may be refused for loading or held and examined on arrival. In practice the rolled cargo, demurrage and detention usually cost far more than the penalty itself.
Can one filing cover repeated shipments from the same supplier?
A single ISF covers one shipment. Importers with regular flows keep verified data on file and run repeated filings against a continuous bond, but any change of supplier, manufacturer, HS heading or ship-to has to be updated before it is reused.
Does moving on a house bill change who files?
No. The house bill affects the carrier's master-level elements only. The importer of record remains responsible for the ten data elements whether the cargo moves on a master bill or a house bill.
Need this handled for a live shipment?
Our team in Chennai handles freight, customs and documentation end to end. Send us the details and we will come back with routing and a rate.
Contact usRelated guides
- Incoterms 2020 Explained for Indian Exporters and Importers
A practical breakdown of all eleven Incoterms 2020 rules: where risk transfers, who pays freight and insurance, and which term to quote for ocean, air and container shipments from India.
- FCL vs LCL: How to Choose, and the Break-Even Volume Nobody Tells You
When full container load beats less-than-container load, how LCL charges really build up, the typical 13–15 CBM break-even point, and how to avoid destination surprises.
- Export Documentation Checklist for India: Every Document, in Order
The complete sequence of documents for an Indian export shipment: proforma invoice, IEC and AD code, shipping bill, bill of lading, certificate of origin, LEO and realisation.