ISF 10+2 Filing: Who Files It and What Fines Apply?

Ten importer data elements, two deadlines, and what a late or wrong filing costs

Brands shipping by sea from Korea often ask us:

"Our forwarder in Busan handles the ISF, right?"

"We ship LCL. Who even knows where our container was stuffed?"

"What happens if the ISF goes in a day late?"

The short answer: the ISF importer files the ISF, usually through a licensed customs broker, and CBP can claim $5,000 for each late or inaccurate filing. The data comes from at least three parties: the Korean exporter, the origin forwarder and the US buyer.

Our importer of record guide covered the IOR, the broker, the bond and the two ISF deadlines. This post goes element by element, then covers penalties and a Busan LCL timeline.

1. Which shipments need an ISF?

The ISF (Importer Security Filing, also called "10+2") applies to cargo arriving by vessel. Under 19 CFR 149.2, bulk cargo is exempt.

LCL counts. CBP's ISF FAQs say an ISF is required for all non-bulk cargo, "regardless of the size of the shipment."
Air freight, including most courier parcels, is outside the rule, since it does not arrive by vessel. Parcels shipped straight to US customers have their own duty rules, covered in our de minimis post.
The ISF is filed at the lowest bill of lading level, which means the house bill of lading (house B/L) when one exists (19 CFR 149.3).

The house B/L is the forwarder's bill; the master B/L is the carrier's. In an LCL container, each brand's house B/L needs its own ISF.

Five cartons in a shared container need an ISF just like a full container does.

2. Who files: the ISF importer is not always the importer of record

Under 19 CFR 149.1, the ISF importer is the party that causes the goods to arrive by vessel. For ordinary imports, that is the goods' owner, purchaser or consignee, or an agent such as a licensed customs broker.

The importer of record (IOR) is a separate role. Its number is element 3 of the ISF and identifies "the entity liable for payment of all duties" (19 CFR 149.3). They can be different companies.

CBP Help Article 1868 says every ISF goes in electronically through ABI or ACE, usually by a licensed broker or a software vendor. A Busan forwarder can collect the data, but someone with ABI or ACE access sends it.

Write down which party is the ISF importer for each lane, and which broker transmits for it.

3. ISF filing data: the 10 importer elements and the 2 carrier elements

19 CFR 149.3 lists the 10 importer elements. The ocean carrier files the "+2": the vessel stow plan and container status messages (CBP mitigation guidelines).

Deadlines are from 19 CFR 149.2. The last column is common practice on Busan LCL shipments, not a CBP rule.

#	ISF element	Legal deadline	Who usually holds the data (Busan LCL)
1	Seller	24 hours before loading	Korean exporter
2	Buyer	24 hours before loading	Korean exporter or US buyer
3	IOR number	24 hours before loading	US importer or its broker
4	Consignee number	24 hours before loading	US importer or its broker
5	Manufacturer (or supplier)	24 hours before loading	Korean exporter
6	Ship-to party	24 hours before loading	US buyer (may be a US 3PL)
7	Country of origin	24 hours before loading	Korean exporter
8	HTSUS number, at least 6 digits	24 hours before loading	Korean exporter, checked by the broker
9	Container stuffing location	24 hours before US arrival	Busan forwarder or consolidator
10	Consolidator (stuffer)	24 hours before US arrival	Busan forwarder or consolidator
+2	Vessel stow plan, container status messages	Carrier deadlines	Ocean carrier

The container number is not one of the 10 elements, though forwarders ask for it on their own forms. The ship-to party is the first receiver after release, often a US warehouse; see when a 3PL makes sense.

Elements 9 and 10 belong to whoever stuffs the container, so the brand rarely has them.

4. ISF-5: cargo that only passes through the US

Transit cargo uses a shorter, 5-element filing (19 CFR 149.3):

FROB (foreign cargo remaining on board): due before loading. The carrier or NVOCC is the ISF importer (19 CFR 149.1).
IE (immediate exportation) and T&E (transportation and exportation), both in-bond moves out of or through the US: due 24 hours before loading (19 CFR 149.2).

The 5 elements are booking party, foreign port of unlading, place of delivery, ship-to party and commodity HTSUS number at 6 digits or more (CBP Help Article 1868).

ISF-5 is for transit cargo; goods sold in the US always need the full 10.

5. Updates, bill match and when a filing counts as late

Under 19 CFR 149.2:

Updates: if any data changes before the goods enter the limits of a US port, the filer must update it.
Best available data: four elements (manufacturer, ship-to party, country of origin and HTSUS number) may go in first as the best data on hand, then be updated no later than 24 hours before arrival. No other element gets this.
Withdrawal: if the goods will not be imported, the filer withdraws the ISF and tells CBP why.

CBP's ISF FAQs add that an ISF filed less than 24 hours before lading is late, measured in practice from the vessel departure date minus 24 hours. The ISF must also match the bill of lading 24 hours before arrival at the first US port.

A booking number on the ISF instead of the real house B/L number can leave the filing unmatched.

6. ISF penalty: $5,000 per violation, and what mitigation looked like

CBP's mitigation guidelines (2018 text) set liquidated damages of $5,000 per late ISF, per inaccurate ISF, and for the first inaccurate update. The claim is made against the bond under 19 CFR 113.62(j), 113.63(g), 113.64(e), 113.73(c) or Appendix D to Part 113.

The same 2018 guidelines describe mitigation:

First violation: the claim may be cancelled on payment of $1,000 to $2,000, depending on mitigating or aggravating factors.
Later violations: not less than $2,500.
CTPAT Tier 2 or Tier 3 members: up to 50% more mitigation.
Data from another party that the filer reasonably believed true: may justify cancellation with no payment.

With no ISF at all, the guidelines say liquidated damages cannot be assessed if no bond is in place. The cargo can still be stuck: CBP may withhold release until it gets the ISF data, limit the permit to unload, or seize the goods. CBP's FAQs say Do Not Load orders at origin are reserved for national security purposes, and an ISF problem is never the only factor.

A US forwarder reported on October 2, 2026 that CBP has been issuing ISF holds and liquidated damages claims, and a broker wrote in September 2026 that CBP is focusing more on data accuracy.

The $1,000 to $2,000 first-violation range is from 2018, so do not plan around it.

7. Executive Order 14411: stricter standards ordered, not yet confirmed

Executive Order 14411, signed June 3, 2026, gave the government 90 days to tighten penalty mitigation. That deadline fell on September 1, 2026. The order calls for:

A penalty floor of at least 50% of the assessed penalty, except in exceptional national security cases
A minimum floor for liquidated damages
No mitigation for repeat offenders

As of October 2026, CBP's Strengthening Customs Enforcement page does not list new standards. Trade press reported on September 4, 2026 that the deadline passed with no action. Ask your broker which standard CBP applies when a claim arrives.

Until CBP publishes the new standards, no one can say how much of a $5,000 claim mitigation will remove.

8. ISF bond and filing fees

An ISF needs a bond: an entry bond can cover it, or a stand-alone ISF bond (Appendix D). Beyond the basics in our customs post, CBP's FAQs add two points:

Unified entry: if you send the ISF and the entry together on a single transaction bond, the bond goes up by $10,000 to cover the ISF part.
Same party: CBP accepts separate bonds for the ISF and the entry, but when the same party is responsible for both, it must use one bond that secures both.

CBP sets no ISF filing fee (GHY); providers set their own. One 2026 broker cost guide puts the typical range at $25 to $75 per ISF. Bond and entry charges are separate and vary by provider.

The filing fee is small next to a $5,000 claim, so ask each provider how it checks your data before it files.

9. A Busan LCL timeline: what to send, and when

Forwarders set a cutoff earlier than the 24-hour legal deadline. One US forwarder asks for the ISF form 48 to 72 hours before loading, with the actual house B/L SCAC (carrier code) and number. A Korea-origin ISF form from 2016 asked for the form and commercial invoice in English 72 hours before sailing.

The Korean exporter sends the forwarder or US broker:

Seller and buyer legal names and addresses
Manufacturer name and address for each product line
Ship-to party: the first US receiver, such as a 3PL warehouse
Country of origin and 6-digit HTSUS number for each line, tied to its manufacturer
Commercial invoice and packing list

The Busan forwarder supplies the house and master B/L numbers with SCAC, vessel, voyage, container number, consolidator and stuffing location.

For example, if an LCL container leaves Busan on a Thursday at 6 p.m., an ISF filed after 6 p.m. Wednesday is late. With a 72-hour cutoff before sailing, your data is due to the forwarder by Monday evening. We found no Korea-specific ISF rule. Confirm the Korean export steps with your forwarder.

Plan the exporter's data around the forwarder's cutoff, which falls a day or two before CBP's deadline.

Four checks before the next sailing

1. Who is the ISF importer for this shipment, and which broker transmits it?

2. Does the ISF carry the real house B/L number and SCAC, not a booking number?

3. Do the manufacturer, origin and 6-digit HTSUS lines match the commercial invoice?

4. Who sends the stuffing location and consolidator, and who updates the filing if the data changes?

Wrap-up

This post summarizes the rules and is not legal advice; for a specific shipment, check with a licensed customs broker or CBP.

LinkONE is an FMC-registered NVOCC that runs Korea-US LCL consolidation, FCL and air freight, and supports US customs clearance and import compliance from its warehouse in Fullerton, California.

In the end, an ISF is late when the slowest party is late, so set the cutoff with all three before the cargo is booked.

Frequently Asked Questions

Who is responsible for the ISF filing?

The ISF importer is responsible: the goods' owner, purchaser or consignee, or an agent such as a licensed customs broker (19 CFR 149.1). For foreign cargo remaining on board, it is the carrier or NVOCC. Every ISF is filed electronically through ABI or ACE (CBP Help Article 1868).

When is the ISF due?

Eight elements are due 24 hours before the cargo is loaded at the foreign port, and the container stuffing location and consolidator are due 24 hours before US arrival (19 CFR 149.2). CBP treats an ISF filed less than 24 hours before lading as late, measured from the vessel departure date minus 24 hours (CBP ISF FAQs).

What is the penalty for a late or inaccurate ISF?

CBP may claim liquidated damages of $5,000 per late ISF, per inaccurate ISF, and for the first inaccurate update (CBP mitigation guidelines). The 2018 guidelines let a first violation be cancelled for $1,000 to $2,000. Executive Order 14411 ordered stricter standards by September 1, 2026.

What happens if an ISF is not filed?

CBP may withhold release of the cargo until it receives the ISF data, limit the permit to unload, or seize the goods (CBP mitigation guidelines). Liquidated damages for a missing ISF need a bond in place. Do Not Load orders at origin are reserved for national security purposes (CBP ISF FAQs).

Do small LCL shipments need an ISF?

Yes. CBP says an ISF is required for all non-bulk ocean cargo, regardless of the size of the shipment (CBP ISF FAQs). It is filed at the house B/L level, so each brand's house B/L in a shared container needs its own ISF (19 CFR 149.3).

Sources

Fees and rules in this post are as of October 2026.

-LinkONE-