ISF - Import Security Filing
What is an Importer Security Filing?
Under the new rule, before merchandise arriving
by vessel can be imported into the United States,
the “Importer Security Filing (ISF) Importer,”
or their agent (e.g., licensed customs broker),
must electronically submit certain advance cargo
information to CBP in the form of an Importer
Security Filing. This requirement only applies to
cargo arriving in the United States by ocean vessel;
it does not apply to cargo arriving by other modes
of transportation.
Who is Responsible for the Filing?
The ISF Importer is required to submit the Importer
Security Filing. The ISF Importer is the party causing
the goods to arrive within the limits of a port in the
United States by vessel. Typically, the ISF Importer
is the goods’ owner, purchaser, consignee, or agent
such as a licensed customs broker.
However, for foreign cargo remaining on board
(FROB), the ISF Importer is the carrier. For
immediate exportation (IE) and transportation and
exportation (T&E) in-bond shipments, and goods
to be delivered to a foreign trade zone (FTZ), the
ISF Importer is the party filing the IE, T&E, or FTZ
documentation.
What Must Be Filed?
Shipments Consisting of Goods Intended to be
Entered into the United States and Goods Intended
to be Delivered to a Foreign Trade Zone
ISF Importers, or their agent, must provide eight
data elements, no later than 24 hours before the
cargo is laden aboard a vessel destined to the United
States. Those data elements include:
Seller
Buyer
Importer of record number / FTZ applicant
identification number
Consignee number(s)
Manufacturer (or supplier)
Ship to party
Country of origin
Commodity Harmonized Tariff Schedule of
the United States (HTSUS) number
DATA ELEMENTS (SPECIFIC)
A. Importer of Record Number
1. Can the importer of record number be a CBP assigned number?
Yes. The IRS number, EIN, SSN, or CAN of the entity liable for payment of all duties
and responsible for meeting all statutory and regulatory requirements incurred as a result
of importation must be provided. However, the consignee number is the IRS number,
EIN, SSN, or CAN of the individual(s) or firm(s) in the United States on whose account
the merchandise is shipped.
2. What identification number is required for parties without U.S. social security numbers
shipping household goods?
In this instance, the passport number, passport country of issuance, and date of birth will
be accepted.
3. Can a foreign entity be identified as the Importer of Record Number?
Yes. However, a U.S. entity must be provided for the consignee number element.
B. Consignee Number
1. What identification number is required for parties without U.S. social security numbers
shipping household goods?
In this instance, the passport number, passport country of issuance and date of birth will
be accepted.
2. The ISF-10 record asks for a Consignee. According to the ISF Implementation Guide, for
unified entry, the EI-10 record is used to report the Ultimate Consignee, not Consignee. Are we
to presume that the Ultimate Consignee and Consignee are the same?
Yes, in this instance the Ultimate Consignee and Consignee must be the same.
C. Ship-to Party
1. If the container has to be de-vanned in more than one location (i.e. container does multiple
stops after arriving in the U.S. and drops cargo off at each location), does 10+2 require listing of
all locations for the ship to addresses? You may see this scenario where it is one company but
has multiple divisions underneath it. Thus, there would be only one BOL reflecting the Importer
of Record (IOR) but several separate divisions under the one IOR. What would CBP want to see
as the ship to location—the first ship-to location or all?
Pursuant to 19 CFR 149.3(a)(6), the name and address of the first deliver-to party
scheduled to physically receive the goods after the goods have been released from
customs custody must be provided. ISF Importers are not required to provide subsequent
ship-to parties; however, they may do so if they choose.
2. Who should be listed as the ship-to party when a shipment is shipped to a distribution facility
that is owned by one company and operated by another related company?
Pursuant to 19 CFR 149.3(a)(6), the name and address of the first deliver-to party
scheduled to physically receive the goods after the goods have been released from
customs custody must be provided. The party physically receiving the goods must be
provided and not an entity that merely owns the facility.
3. Please provide clarification regarding the data element “ship-to name and address”. It would
be helpful to have explanatory examples. The requirement is for the name and address of the
first deliver-to party scheduled to physically receive the goods after the goods have been
released from customs custody.
Please address the following scenarios:
a. Full container load (FCL) cargo clears prior to arrival at the port of discharge. Is the
terminal/pier the ship-to, since the cleared freight is no longer in customs custody? How
would the ISF filer know this 24 hours prior to lading?
In this scenario, the terminal was not the first deliver-to party scheduled to
physically receive the goods after the goods have been released from customs
custody. Rather, the party who was scheduled to physically receive the goods at
the time of the ISF filing must be provided.
b. FCL cargo moves in-bond to an inland point by rail. After clearance at the inland port,
the container is delivered to the ultimate consignee. Is the ship-to party the railroad,
since they receive the cargo first after the freight leaves the pier, or is it the ultimate
consignee since they receive the cargo first after Customs clearance?
The bonded carrier should not be provided as the ship-to party. In this example,
the identity of the ultimate consignee should be provided as the ship-to party.
c. FCL or LCL cargo moves on a Permit to Transfer to a Container Freight Station (CFS)
warehouse for loading to trucks for delivery. The cargo clears Customs while at the
CFS. Is the ship-to the CFS, or is it the ultimate consignee?
The identity of the first deliver-to party scheduled to physically receive the goods
after the goods have been released from customs custody must be provided. In
this instance, CBP wants the ultimate consignee’s physical address where the
goods are scheduled to be received.
D. Manufacturer (Supplier) Name/Address
1. We import containers with thousands of parts, potentially having literally hundreds of
different manufacturers, from a related party who, in turn, purchases the parts from those
manufacturers. These parts may be commingled prior to importation. On the ISF, can we
provide the identity of our related party to fulfill the Manufacturer (Supplier) ISF requirement as
this is the party from whom we actually buy the parts or do we need to list all the manufacturer's
individually?
The party who supplied the goods can be provided as long as that party is a separate legal
entity from the ISF Importer. If both of these parties are the same entity, the identity of
the party who last manufactured, assembled, produced, or grew the commodity or the
party who supplied the finished goods to the ISF Importer must be provided. Generally,
the manufacturers provided on the CBP Form 3461 will satisfy the ISF requirement.
2. Please advise if we need to submit both the manufacturer and the supplier info on the 10+2
ISF filing. Or will the supplier data be sufficient?
The identity of the entity that last manufactures, assembles, produces, or grows the
commodity or the name and address of the party supplying the finished goods in the
country from which the goods are leaving must be provided. However, CBP would
prefer that the identity of the actual manufacturer be provided where that entity is known.
3. Can the manufacturer (supplier) be a U.S. company?
The manufacturer (supplier) can be U.S. a company if the party that last manufactured,
assembled, produced, or grew (or supplied) the commodity is a U.S. company.
E. Country of Origin
1. If the merchandise is assembled in one country, but parts are from many other countries,
which country of origin do I list?
Generally, the country of origin for the imported product that is provided on the CBP
Form 3461 will satisfy the ISF requirements.
2. Can you advise if the country of origin needs to be linked to each Harmonized Tariff
Schedule of the United States (HTSUS) number or is it enough that the data is given
electronically against each part number?
The manufacturer (or supplier), country of origin, and commodity HTSUS number must
be linked to one another at the line-item level. This linking is similar to the CBP Form
3461 requirements. Line-item linking is required at the ISF shipment level and not at the
invoice, container, parts or bill of lading level.
F. Commodity HTS-6
1. When you talk about line-item linking requirement, are you talking at the HTS 6-digit level or
at a SKU level on the commercial invoice from the manufacturer/supplier? I am asking as we
have shipments from one manufacturer/supplier that might contain 100 different SKUs but
would only result in five HTS numbers.
If the 100 different SKUs result in just five HTS numbers at the 6-digit level, the ISF
Importer or its agent may provide the five HTS numbers. However, the manufacturer (or
supplier), country of origin, and commodity Harmonized Tariff Schedule of the United
States (HTSUS) number must be linked to one another at the line-item level. This linking
is similar to the CBP Form 3461 requirements. Line-item linking is required at the ISF
shipment level and not at the invoice, container, parts or bill of lading level.
2. Parts: If an importer of parts brings in container loads of thousands of parts with multiple
manufacturers, countries of origin, and HTSUS numbers, does the importer, upon filing the ISF,
have to show every part’s HTSUS number or can they show a general number such as
8714.190060 which is parts and accessories of motorcycles? The exact parts in the shipment
may not be known upon filing the ISF and since 8714.190060 is specifically parts and
accessories of motorcycles, is it acceptable?
The duty/statistical reporting number under which the article is classified in the HTSUS
must be provided. The HTSUS number must be provided to the 6-digit level. The ISF
Importer can submit an initial response or responses based on the best available data at
the time of the filing. However, the ISF must be updated as soon as more precise or more
accurate information is available in no event less than 24 hours prior to arrival at a U.S.
port (or upon lading at a foreign port that is less than a 24-hour voyage to the closest U.S.
port).
3. How many HTS digits are required for foreign cargo remaining on board (FROB)?
The commodity HTSUS number for FROB cargo must be provided to the 6-digit level.
The HTSUS number may be provided to the 10-digit level.
4. Garments on hangers: At the time of shipping, our electronic purchase orders that we provide
to our overseas third-party logistics provider do not specify when garments will ship with
hangers. Upon entry, however, our U.S. customs brokers have this information and classify the
hangers separate from the garments because they qualify for the lower duty treatment. For ISF
purposes, do we need to provide the 6-digit HTS number for the hangers in addition to the HTS
number for the garments that are hanging on them?
The ISF needs to include the 6-digit HTS number for the hangers if the ISF Importer is
aware of the existence of the hangers. If the ISF Importer is initially unaware that the
hangers are shipped with the garments, then the ISF Importer should update the ISF as
soon as they become aware of this information.
G. Container Stuffing Location
1. If a single container is stuffed in multiple locations, must I enter all locations into the ISF?
Yes. When a container is stuffed at more than one location and/or more than one
container is on a single bill of lading, all of the stuffing locations for the goods listed on
the bill of lading must be provided.
2. The interim final rule states that for break bulk cargo the Container Stuffing Location should
be the party that made the goods 'ship-ready.' This term is somewhat vague when it comes to
the shipping of motor vehicles on Ro-Ro vessels. Does 'ship-ready' refer to the preparation for
transport of the vehicle such as the application of protective tape and suspension blocks, or does
it refer to the actual movement onboard the vessel and lashing of the vehicle?
Ship-ready refers to the location(s) where the cargo is made ready (taped, banded,
packaged, etc.) to be laden on the vessel. This could be the factory, terminal, intermediate
warehouse, or other location.
3. I need a simple way to explain what Container Stuffing Location and Consolidator (Stuffer)
mean to my foreign shippers. Do you have anything that explains exactly what these two data
elements are, and how my shippers can obtain the information, in simple terms?
The container stuffing location(s) are the physical location(s) where the goods were
stuffed into the container. This does not mean the location of the goods within the
container. For break bulk shipments, this is the physical location(s) where the goods
were made ship-ready.
The consolidator (stuffer) is the party who stuffed the container or arranged for the
stuffing of the container. For break bulk shipments this is the party who made the goods
ship-ready or arranged for the goods to be made ship-ready.
4. An export shipment is loaded into a container at a facility in Germany in which the brick and
mortar, as well as the goods in the facility, are owned by Company AG. However, the facility is
operated by a related firm, Company AG Logistics Services. Who would be listed as the
Container Stuffing Location for the ISF; Company AG or Company AG Logistics Services?
Provide the name of the operator of the facility and the address of the facility where the
goods were stuffed into the container or made ship-ready.
H. Consolidator (Stuffer) Name/Address
1. If there are multiple stuffing locations and there are multiple consolidators, do all
consolidators need to be listed? An example would be an NVOCC doing a milk run where it
stops at multiple locations and the container is stuffed at each location by a different party.
Would all stuffers need to be listed for just the party who arranged for the stuffing?
In this scenario, the name of the party that arranged for the stuffing of the container
should be provided.
2. Who would be shown as the Consolidator or Stuffer for a “Shipper Loaded” Container that is
shipped by a manufacturer directly with the steamship line?
If the manufacturer is the party that stuffed the container or arranged for the container to
be stuffed, then the manufacturer is the consolidator (stuffer).
3. If I have one shipment going to one importer that has multiple containers which are stuffed by
various consolidators, do I have to list them all as part of my ISF?
Yes. It is important to note that there can be more than one consolidator involved in a
transaction. CBP requires that if multiple consolidators are involved (e.g., some co-load
situations) then multiple consolidators need to be provided as part of the ISF.