ISF filing requirements: who files, the 10 elements, and the 24-hour rule

An ISF applies to cargo arriving by vessel. The importer, or an authorized agent such as a licensed customs broker, sends ten data elements to CBP, the first eight no later than 24 hours before the cargo is loaded on the vessel at the foreign port.

Who files

The ISF is filed by the “ISF Importer” (19 CFR 149.1 ): the party causing goods to arrive within the limits of a US port by vessel. For ordinary shipments that is the goods’ owner, purchaser, consignee, or an agent such as a licensed customs broker. The filing may be submitted by the importer or an authorized agent, in English, through a CBP-approved electronic system (149.2(a) ).

The ISF importer must have a bond that satisfies 19 CFR 149.5(b); if it does not, the agent submitting for it may post the agent’s bond. A filer must have the communication protocol CBP requires (149.5 ). Whether you can file it yourself depends on that access.

What is required

Ten elements for each good, listed at the six-digit HTSUS level, at the lowest bill of lading level (149.3(a) ): seller, buyer, importer of record number, consignee number(s), manufacturer (or supplier), ship-to party, country of origin, commodity HTSUS number, container stuffing location, and consolidator (stuffer). The manufacturer, country of origin and commodity HTSUS number must be linked to one another at the line level. A ready checklist of the ten elements follows the regulation.

When

What it does not cover

The requirement is for “cargo arriving by vessel” (149.2(a) ), so it is not an air cargo filing. Bulk cargo that is exempt from the 24-hour cargo declaration is also exempt from the ISF, and break bulk cargo has a different time requirement (149.4 ).

Penalties for late or wrong filings, and how CBP mitigates them, are on ISF late filing penalty . The bond is on ISF bond , and the messages CBP sends back on ISF status codes .

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