ISF 10+2 Explained: Who Files What, NVOCCs and Carriers Included


By GDZ Computer Services · Updated 2026-10-21 · 8 min read · Blog › U.S. Customs and compliance

ISF 10+2 is CBP's Importer Security Filing rule for cargo arriving by vessel: the importer side files ten data elements before loading, and the carrier side provides two more, the vessel stow plan and container status messages. NVOCCs sit in the middle, so it helps to know exactly which part is theirs.

Key takeaways
  • The “10” are importer elements filed by the ISF Importer or its agent, most of them no later than 24 hours before cargo is laden at the foreign port.
  • The “+2” belong to the vessel carrier: a stow plan due within 48 hours after leaving the last foreign port, and container status messages within 24 hours of recording the event.
  • For cargo remaining on board (FROB), the carrier or NVOCC is the ISF Importer and files five elements before lading.
  • A party filing ISF under an international carrier bond agrees to liquidated damages of $5,000 for each violation.

What ISF 10+2 is and why it exists

The Importer Security Filing rule, formally “Importer Security Filing and Additional Carrier Requirements”, applies to import cargo arriving in the United States by vessel. CBP lists its effective date as January 26, 2009 (CBP: Importer Security Filing 10+2), and the regulation at 19 CFR 149.2 sets the general compliance date as January 26, 2010. CBP warns that failing to comply can lead to monetary penalties, more inspections and delayed cargo.

The name describes the split. Ten data elements come from the importer side, describing who sold and bought the goods, who made them, where they come from and where they were stuffed. Two come from the carrier side and describe the vessel and the containers. Together with the carrier's advance cargo declaration (the ACE manifest), they let CBP screen a shipment before it is loaded abroad.

The 10 importer elements and their deadlines

The elements are defined in 19 CFR part 149. They are reported for each good at the six-digit HTSUS level at the lowest bill of lading level, which means the house bill when there is one.

ElementWhat it isDeadline
1. SellerLast known entity that sold or agreed to sell the goods24 hours before lading at the foreign port
2. BuyerLast known entity to whom the goods are sold24 hours before lading
3. Importer of record number / FTZ applicant IDIRS, EIN, SSN or CBP-assigned number24 hours before lading
4. Consignee number(s)Number of the U.S. party on whose account the goods are shipped24 hours before lading
5. Manufacturer (or supplier)Entity that last made, assembled, produced or grew the goods24 hours before lading
6. Ship to partyFirst party scheduled to physically receive the goods after release24 hours before lading
7. Country of originCountry of manufacture, production or growth24 hours before lading
8. Commodity HTSUS numberAt least six digits, up to ten24 hours before lading
9. Container stuffing locationWhere the goods were stuffed into the containerAs early as possible, no later than 24 hours before arrival at a U.S. port
10. Consolidator (stuffer)Party that stuffed the container or arranged itAs early as possible, no later than 24 hours before arrival
ISF importer elements and timing, from 19 CFR 149.2 and 149.3.

The rule has some flexibility. For manufacturer, ship to party, country of origin and HTSUS number, the ISF Importer may first file the best data available and must then update it as soon as better information exists, and no later than 24 hours before arrival at a U.S. port. The filer also has to update the ISF whenever information changes before the goods arrive, and withdraw it, with a reason, if the goods will no longer be imported.

The “+2”: what the carrier provides

The two carrier elements are not filed by the importer at all. They are obligations of the incoming vessel carrier under 19 CFR 4.7c and 4.7d:

  • Vessel stow plan. Vessel name and IMO number, operator and voyage, and for each container its operator, equipment number, size and type, stow position, hazmat code if any, port of lading and port of discharge. CBP must receive it no later than 48 hours after the vessel departs the last foreign port, or before arrival for voyages shorter than 48 hours.
  • Container status messages (CSMs). Events such as booking confirmed, gate in and gate out, loaded and unloaded, vessel departure and arrival, and stuffing or stripping. A carrier only has to send the messages it already creates or collects in its equipment tracking system, within 24 hours after the message is entered.

Vessel bulk and break bulk carriers have their own exemptions, and an exclusively bulk or break bulk vessel does not need a stow plan. The carrier's cargo declaration itself is a separate filing; see what ACE AMS manifest filing is and who must file.

Where NVOCCs fit in

This is where most confusion starts. The ISF Importer is defined in 19 CFR 149.1 as the party causing the goods to arrive in the United States, which for imported cargo is the goods' owner, purchaser, consignee or an agent such as a licensed customs broker. An NVOCC is usually not the ISF Importer for cargo entering the U.S. commerce. It does, however, carry information the importer needs, such as the stuffing location and consolidator for its own consolidations, and it may act as the importer's authorized agent if it has the CBP connection to file.

Two situations change the picture. For FROB, foreign cargo that stays on board while the vessel calls at U.S. ports, the regulation makes the carrier or the NVOCC the ISF Importer. For shipments moving in-bond as an immediate exportation (IE) or transportation and exportation (T&E), the party filing the IE or T&E documentation can be the ISF Importer. In these cases a shorter set of elements applies.

The FROB, IE and T&E element set is often called “ISF-5”: booking party, foreign port of unlading, place of delivery, ship to party and commodity HTSUS number. For FROB it is due before lading at the foreign port; for IE and T&E, 24 hours before lading.

Bonds, agents and liability

Every ISF Importer must hold a bond that covers ISF obligations. The regulation accepts a basic importation and entry bond, a custodial bond, an international carrier bond, a foreign trade zone operator bond or a dedicated ISF bond. If the importer has none of these, the agent filing for it may post the agent's bond.

For a carrier or NVOCC, the relevant one is usually the international carrier bond. Its conditions in 19 CFR 113.64(f) state that if the principal elects to provide ISF information and defaults, the principal and surety agree to pay liquidated damages of $5,000 for each violation. Agents must also keep powers of attorney in English until revoked, and keep revoked ones for five years. Confirm with your customs broker or surety how your specific bond is written.

Liquidated damages are not the only exposure. Cargo whose security data is missing or inconsistent tends to draw questions and examinations, and the cost of a delayed container usually falls on the party closest to the customer, which is often the NVOCC. Our guide on avoiding CBP manifest penalties and holds covers the data problems that most often trigger them.

A practical ISF checklist for NVOCC operations

Even when the importer files the ISF, the NVOCC's data drives much of it. A short routine prevents most problems:

  1. At booking, capture the U.S. consignee, the actual seller and buyer, and the manufacturer, not just the forwarder at origin.
  2. Confirm who is filing the ISF for each house bill and send them your container number, stuffing location and consolidator as soon as the box is closed.
  3. Use the same parties, piece counts and descriptions on your house bill, your ACE manifest and the data you send the ISF filer.
  4. Check that the HTSUS number given for ISF matches the cargo description you manifest.
  5. When a booking is cancelled or rolled, tell the ISF filer so the filing can be updated or withdrawn.

Doing this by hand across e-mail threads is where shipments slip. Systems such as GDZ-ISIS for NVOCCs keep the booking, the house bill of lading and the customs data in one record, which makes it easier to hand clean, consistent data to whoever files.

Frequently asked questions

Who files ISF, the NVOCC or the importer?

For goods entering U.S. commerce the ISF Importer is the owner, purchaser, consignee or its agent, such as a licensed customs broker. An NVOCC files only if it is that agent, or when it is the ISF Importer for FROB cargo.

When is the ISF due?

Most importer elements are due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port. The container stuffing location and consolidator are due as early as possible and no later than 24 hours before arrival at a U.S. port.

What are the carrier's two ISF elements?

The vessel stow plan and container status messages. The stow plan is due within 48 hours after departure from the last foreign port, and CSMs within 24 hours after the carrier records the event.

What is ISF-5?

It is the common name for the five elements required for FROB cargo and for in-bond shipments moving as an immediate exportation or as a transportation and exportation: booking party, foreign port of unlading, place of delivery, ship to party and commodity HTSUS number.

What is the penalty for a late or wrong ISF?

Under the international carrier bond, a principal that elects to file ISF and defaults agrees to liquidated damages of $5,000 per violation. CBP also warns of more inspections and delays. Ask your customs broker about current enforcement.

Sources

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