Importer Security Filing:

The Importer Security Filing, or "ISF", formally 10+2, is a new security filing requirement imposed on all U.S. importers for goods arriving at U.S. Seaports.

Each ocean shipment is required to have an ISF filed no later than 24 hours prior to lading at a foreign port. The filing is to consist of ten data elements, and must be secured by a bond. ISF Importers may elect to self-file or, as a business decision, contract the filing to a filing agent (such as a Customs broker or AMS participating forwarder.) Violations of the ISF regulations will result in a $5000 penalty per violation.

The effective date of the filing requirement is for shipments loaded to vessel on or after Jan. 24th, 2009. There will be a 12 month flexible enforcement period, during which CBP will refrain from issuing penalties for violations, provided that the ISF Importer shows progress in meeting the requirements during that time.

RGA Importer Security Filing Procedure:

Our customers have 2 options for ISF filings through RGA Logistics.

Importer Requirements:

The interim final rule requires Importer Security Filing (ISF) importers, or their agents to provide eight data elements, generally no later than 24 hours before the cargo is laden aboard a vessel destined to the United States, for shipments consisting of goods intended to be entered into the United States and goods intended to be delivered to a foreign trade zone (FTZ). Those data elements include:

• Seller Name & address of the last known entity by whom the goods are sold or agreed to be sold.
• Buyer Name & address of the last known entity to whom the goods are sold or agreed to be sold.
• Importer of record number IRS, EIN, Social Security or CBP assigned number belonging to the entry importer of record.
• Consignee number IRS, EIN, SSN or CBP assigned number of the party for whose account the merchandise is shipped (reported as the ultimate consignee for entry purposes).
• Manufacturer or supplier Name & address of the entity that last manufactures, assembles, products or grows the commodity, or name & address of the party supplying the goods in the country from which the goods are leaving. Alternately, the party currently required by import laws, rules and regulations for standard entry procedures may be utilized.
• Ship to party Name & address of the first deliver-to party scheduled to physically receive the goods after release from Customs custody. A DUNS number is acceptable in lieu of the name & address, provided the DUNS number is registered to the actual location of the ship to party.
• Country of origin Country of origin as required per existing laws, rules & regulations.
• Commodity HTSUS number Tariff number of each invoice line, to the six digit level. The full ten digit statistical number may be used, but can only be used for both ISF and entry purposes if filed by the importer of record or its licensed Customs broker.
• Container stuffing location Name & address of the physical location where the goods were loaded to the
• Consolidator (stuffer) Name & address of the party who stuffed, or arranged for stuffing of, the container.

The rule provides flexibility for importers with respect to the submission of four of these data elements. In lieu of a single specific response, importers may submit a range of responses for each of the following data elements: manufacturer (or supplier), ship to party, country of origin, and commodity HTSUS number. The ISF must be updated as soon as more accurate or precise data becomes available and no later than 24 hours prior to the ship's arrival at a U.S. port.

The ISF will also need to include two data elements that must be submitted as early as possible, but no later than 24 hours prior to the ship's arrival at a U.S. port. These data elements are:

• Container stuffing location Name & address of the physical location where the goods were loaded to the
• Consolidator (stuffer) Name & address of the party who stuffed, or arranged for stuffing of, the container.

In addition, the rule requires that the Importer Security Filing for shipments consisting entirely of foreign cargo remaining on board (FROB) and shipments consisting entirely of goods intended to be transported in-bond as an immediate exportation (IE) or transportation and exportation (T&E), must provide five elements. Importer Security Filings for IE and T&E shipments must be submitted no later than twenty-four hours before the cargo is laden aboard a vessel destined to the United States and Importer Security Filings for FROB must be submitted any time prior to lading. The following five data elements must be submitted for FROB, IE and T&E shipments:

• Booking party;
• Foreign port of unlading;
• Place of delivery;
• Ship to party; and
• Commodity HTSUS number.

Structured Review and Flexible Enforcement Period:

CBP has made several significant changes from the proposed rule, based on public and stakeholder feedback. The interim final rule also includes a delayed compliance date of 12 months after the interim final rule takes effect. During this 12-month period, CBP will show restraint in enforcing the rule. CBP will take into account difficulties that importers may face in complying with the rule as long as importers are making a good faith effort and satisfactory progress toward compliance.

In addition, CBP will conduct a review to determine any specific compliance difficulties that importers and shippers may experience in submitting all 10 data elements 24 hours before lading. The structured review will cover a range of enterprises, from small to large, and will include both integrated and nonintegrated supply chains.

We Understand

Your shipments are Time Critical. Our goal is to routinely seek ways in which we can move your product more efficiently.

ISF Resources

ISF FAQ
ISF Final Ruling