ISF/10+2 Are You Ready For Enforcement?

The ISF rule took effect Jan. 26, 2009, full enforcement will take effect on Jan. 26, 2010, following a year of education, outreach and informed compliance efforts.  As of that date, importers will be subject to fines of $5,000 each time an ISF filing is late or inaccurate.  Importers could face a maximum penalty of $10,000 on one shipment if you file late and have erroneous data.  Mitigating circumstances include evidence of progress in the implementation of the ISF requirement during the flexible enforcement period (i.e., January 26, 2009 through January 26, 2010). 

Under the ISF rule, importers and maritime cargo carriers must submit additional cargo data to CBP 24 hours prior to vessel loading.  Importers are legally responsible for the accuracy and timeliness of their ISF filings, regardless of whether a customs broker or other intermediary does the actual filing.  Importers have to report 10 data elements on each ISF, including information that identifies the manufacturer, supplier, seller, buyer and consignee; the country of origin and tariff classification number; where and by whom the goods were stuffed into the container; and the party responsible for compliance with applicable import requirements.  CBP’s goal is to have all data elements filed 24 hours prior to lading, but it has allowed for some flexibility either in timing or interpretation for six of the data elements.

There have been many obstacles in ISF implementation. The largest problem has been the carriers and bills of lading numbers. It is imperative the data is reported at the lowest AMS bill of lading number. To avoid problems you must know your carriers.  Not all carriers are alike, be extra careful with non-AMS filing carriers.  CBP requires ISF filings match AMS and entry data. 

Please do not wait until the last minute. DTGruelle can help you with your ISF/10+2 transactions. Please contact Barbara Bachurski at This e-mail address is being protected from spambots. You need JavaScript enabled to view it , Danelle Tanner at This e-mail address is being protected from spambots. You need JavaScript enabled to view it , or Jessica Bachurski at This e-mail address is being protected from spambots. You need JavaScript enabled to view it for details.