Importer Security Filing and
Additional Carrier Requirements
Korean Chamber of Commerce
April 5, 2011
Today’s Presentation on “10+2”
Top ISF Issues
Q & A Session
Los Angeles - Long Beach Seaport
What is the Security Filing?
The Security Filing, commonly known as the “10+2” initiative, is a Customs
and Border Protection (CBP) regulation that requires importers and vessel
operating carriers to provide additional advance trade data to CBP pursuant to
Section 203 of the SAFE Port Act of 2006 and section 343(a) of the Trade Act
of 2002, as amended by the Maritime Transportation Security Act of 2002, for
non-bulk cargo shipments arriving into the United States by vessel.
U.S. Bound Cargo (Includes FTZ and IT) : requires the electronic filing of an
Importer Security Filing (ISF) comprised of 10 data elements.
Transit Cargo (FROB, IE and TE): requires the electronic filing of an
Importer Security Filing (ISF) comprised of 5 data elements.
Vessel Stow Plans required for arriving vessels with containers.
Container Status Messages required for containers arriving via vessel.
Importer Security Filing (ISF) Importer
The party required to submit the Importer Security Filing (ISF) is
the party causing the goods to enter the limits of a port in the
United States. This party is known as the “ISF Importer”.
Could be the owner, purchaser, consignee, or agent (e.g. customs
For foreign cargo remaining on board (FROB), this party is the
carrier (vessel operating carrier).
The party filing the immediate exportation (IE), transportation and
exportation (T&E), or foreign trade zone (FTZ) documentation is the
ISF Importer for those types of shipments.
The ISF Importer is ultimately responsible for the timely,
accurate and complete submission of the ISF filing.
The ISF Importer, as a business decision, may designate an
authorized agent to file the Importer Security Filing on the ISF
If an agent is used for ISF purposes, a power of attorney (POA) is required.
Agents must have access to one of CBP’s approved automated
systems. For ISF requirements, the approved systems are the vessel
Automated Manifest System (AMS) and the Automated Broker
The filing of an ISF does not constitute “customs business”.
Exception is the “Unified Entry” filing.
The Vessel Operating Carrier (VOC) may hire a Non-Vessel
Operating Common Carrier (NVOCC), or another party, to be its
agent for ISF purposes.
ISF-10s “By the Numbers”
January 1, 2011 – March 29, 2011
Total Submissions: 2,098,184
Total Rejected: 36,782 2%
Total Accepted: 2,061,402 98%
Note: Do NOT send
in a “REPLACE” to
simply force an ISF-
Filers: 2,000+ Bill match message!
Importers (IOR #s): 120,500+
Total Carrier-Related Filings
January 1, 2011 – March 29, 2011
Stow Plans 4,966
ISF-10 Data Elements
“U.S.-bound” Cargo (3461 Entries, IT, FTZ)
1. Importer of Record Number
2. Consignee Number
3. Seller (Owner) name/address
4. Buyer (Owner) name/address
5. Ship to Party
6. Manufacturer (Supplier) name/address
7. Country of Origin
8. Commodity HTS-6
9. Container Stuffing Location
10. Consolidator (Stuffer) name/address
11. Bill of Lading Number (house or reg.)
12. ISF Importer
CBP Form 3461
ISF Filing Requirements
Before an ISF or the ISF process can be considered
“finished”, the ISF must be:
The ultimate responsibility rests with the ISF Importer!
The check for ISF completeness is largely done by system edits
The ISF Filer receives an initial system notification message
Accepted with Warning (an update may be required)
Postal Code was not provided
All “Flexible Filings” must be updated
Rejected (need to start over)
Bill of lading number missing or in incorrect format
Some of the required ISF data was missing
If the ISF is accepted, CBP sends a unique transaction number
Electronic Receipt that an ISF was submitted and accepted (BUT NOT FINISHED!!!)
Includes a date and time so it can be compared to the vessel departure message
Includes properly matching the ISF to a bill of lading at the lowest
level in AMS
A match or no-match message is sent back to the ISF Filer
S1 “Bill on File” Generated when the ISF is matched to an AMS bill of
S2 “No Bill Match (Not on File)”
No great cause of concern. Many times, the ISF precedes the manifest filing
S3 “No Bill Match (Not on File)” Still no match 5 days after ISF
S4 “No Bill Match (Not on File)” Still no match 20 days after ISF
S5 “No Bill Match (Not on File)” Still no match 30 days after ISF
S6 “No Bill Match (Wrong Type)”
S7 “Duplicate ISF by Another Filer”
Accurate ISF: ABI Bill of Lading Query
CBP updated the Automated Broker Interface (ABI) bill of lading
query to help ISF Filers and ISF Importers obtain the correct bill
of lading numbers and bill of lading types to use on their ISFs.
If a bill of lading number is queried, CBP will return back the bill type (i.e.,
Master, house, or Regular/Simple/Ocean)
If a Master bill of lading number is queried, CBP will also return back all of the
house bill of lading numbers.
If a house bill of lading number is queried, CBP will also return back the correct
Master bill of lading number.
Note: the bill of lading numbers need to be on file for the query
to work properly. In many instances, the ISF will be filed prior to
the manifest being filed.
CBP regulations generally require that an ISF be submitted
electronically no later than 24 hours prior to vessel lading
(Anytime prior to lading for FROB)
CBP is using the vessel departure message minus 24 hours to
establish “timeliness” since it is the closest available metric.
Flexible filings MUST be updated as soon as the new
information is known, but under no circumstances later than 24
hours prior to arrival.
CBP maintains a record of all ISF filings including unmatched,
rejected and deleted ones.
C-TPAT Benefits of “10+2”
Customs - Trade Partnership Against Terrorism
Earlier Decision Making
C-TPAT entities are reliably identified prior to vessel lading
Based on Importer of Record Number on the ISF
No longer tied solely to entry data (24 hours or more prior to arrival)
Better Decision Making
Tangible C-TPAT benefits are applied much further upstream
Receive targeting credit based upon their tier status
Stabilization of Automated Hold Process
Immediate Transportation (IT) in-bond risk assessments are more stable
Validation of Supply Chain Security Reviews
New Entities and Locations Identified and/or Verified
Container Stuffing Location
Consolidator (Stuffer) name/address
“10+2” Program Update
Top Five Error Messages
ISF-10 Errors Top Five Error Messages (1/26/2010 to 8/5/2010)
Note: A single ISF may have multiple errors. Not
all errors lead to an ISF rejection (most do).
Duplicate ISF Invalid BOL Entitiy Identifier ISF Transaction# Invalid HTS #
Format Not on File Not on File
21% 5% 4% 3% 3%
“10+2” Enforcement Strategy
CBP’s Vessel Stow Plan Module
Used to identify unmanifested containers
ISF Enforcement Strategy
The full compliance (enforcement) date for the “10+2”
requirements commenced on January 26, 2010, thus ending a
12-month delayed enforcement period in which CBP provided
extensive outreach to educate the trade community on the new
requirements. CBP is:
Applying a measured, commonsense approach to
Exercising the least amount of force necessary to obtain full
Evaluating non-compliance on a case-by-case basis
Continuing to provide outreach and guidance to the trade
Informed Compliance Efforts
Public outreach (incl. webinars, meetings, ISF Progress Reports)
Informal and formal notification (e.g., warning letters)
Mid-level Compliance Measures
Domestic NII examination manifest holds
Domestic physical examinations
Re-evaluation and possible reduction of C-TPAT status
Strictest Enforcement Measures
ISF Jail (i.e., lengthier manifest holds)
Suspension or Revocation of C-TPAT Status
Do Not Load or Do Not Discharge Orders
Top ISF Issues Identified
Do I need to file 24 Hours prior to lading of the feeder or
The ISF is due 24 hours prior to lading of the mother vessel
Which bill of lading number do I use?
Must use the lowest bill of lading transmitted in AMS (house or regular)
Contact your shipper
New ABI query functionality helps
CBP allows for the bill of lading number to be updated on the ISF
Top ISF Issues Identified
I didn’t receive the ISF “Bill on File” match message.
This is common when the ISF filing precedes the filing of the customs
manifest (i.e., bill info).
Make sure you (or your agent) annotated the correct bill type on the ISF.
Regular Bill – This bill type is also referred to as an “Ocean" or “Simple Bill”
and is issued by a Carrier. There are no underlying house bills.
House Bill – Typically issued by a NVOCC (sometimes referred to as an
automated freight forwarder). A house bill of lading always falls under a
carrier’s Master bill of lading.
ISFs cannot be filed against Master Bills
Do NOT Send in a “REPLACE” to force an ISF-Bill Match message
Go to: www.CBP.gov
Copy of the Interim Final Rule
ISF PowerPoint Presentation
General Frequently Asked Questions (FAQs) Document
Copy of the Regulatory Assessment
Implementation Guides (Technical File Formats)
Richard Di Nucci, Director, Cargo Control Division
John Jurgutis, Branch Chief, ISF & Vessel Manifest
Stephen Silvestri, Branch Chief, Air & Rail Manifest
Craig Clark, Program Manager, ISF
Joseph Martella, Program Manager, New York Field Office