7 Importer Security Filing (ISF) Best Practices You Shouldn’t Ignore

Jane Taeger, Shapiro Director of Compliance, warns importers of the dangers of improper ISF filing.
Jane Taeger, Shapiro Director of Compliance, warns importers of the dangers of improper ISF filing.

The Importer Security Filing (ISF) began in January 2009 with a one year introductory phase-in period. Full enforcement began in January 2010, but Customs and Border Protection (CBP) maintained a flexible and measured enforcement stance. Penalty guidelines were published in July 2009, but Customs held off doing anything until July 2013 when they announced they would begin full enforcement for real and start issuing liquidated damages against ISF importers and carriers for non-compliance. Liquidated damages (which are essentially penalties backed up by a Customs bond) are being issued, but the ports must submit the cases to CBP headquarters for review first. This will be the procedure for at least until mid-2014. HQ has rejected multiple cases from the ports, but has issued penalties against egregious ISF offenders.

Liquidated damages for ISF start at $5000 for failure to file an ISF, $5000 for late ISF, $5000 for inaccurate ISF, $5000 for an incomplete ISF, and $5000 for failure to withdraw an ISF. The maximum liquidated damages per ISF filing is $10,000.

Now that Customs is in full enforcement mode with real liquidated damages for real money, we wanted to share some best practices for your ISF program:

  1. Don’t wait until the last minute:  ISF must be filed at least 24 hours prior to vessel departure. File the ISF as soon as you are able. Make sure to get the information to the filer no later than 72 hours prior to sailing. This will allow time for holidays and weekends.
  2. Use a template:  Save time and reduce your likelihood for errors by using a template.  If you don’t have one, use our Import Security Filing ISF Template.
  3. Hold your suppliers responsible:  Build language into your vendor manuals, purchase orders, contracts, letters of credit, etc., with your ISF expectations to hold your suppliers accountable for providing the ISF data and providing it timely. If you receive a penalty for a late ISF, make sure you have a clause that will require the supplier to take responsibility for the cost if they are at fault.
  4. Use a continuous bond: A Customs continuous entry bond will cover both the ISF and the Customs entry. If you do not have a continuous bond, you will need a separate ISF bond for each filing. If the ISF is late, the surety company will likely ask for collateral of $5000 to secure the bond. Need a continuous bond?  Contact us.
  5. Don’t be afraid to amend your ISF filing:  Update the ISF if you need to amend any information. Do not sacrifice a timely ISF by deleting it and refiling late. ISFs can be updated at any point up to the time the cargo arrives in the U.S.
  6. Get a bill of lading (B/L) match:  Make sure you get a bill of lading match at least 24 hours prior to cargo arrival. If you get an “AMS Bill Not on File” message, do not resend the ISF to try to force a match. Do double-check the bill of lading number to be sure it is correct and is the lowest level bill number on file in Automated Manifest System (AMS). If it is, the match will occur once the carrier files the manifest. If the vessel sails and a couple of days later you still don’t have a match, then you should contact your supplier to verify the bill of lading information.
  7. Monitor your monthly ISF progress report:  The party filing your ISF receives these reports through their Automated Commercial Environment (ACE) portal and should be forwarding them to you. The reports detail the number and types of errors occurring as well as your ISF on time percentage.

Have any other ISF best practices to share?  Leave me a comment below.

p.s. For more information on ISF, download What You Need to Know About Importer Security Filing (ISF).

-- Jane L. Taeger
Director of Compliance


  • Basaria

    Hi jane.
    May i ask you? I just realized, i sent ISF on 5 oct which mother vessel departured on 3oct. It will be any pinalties from us custom for late submission? While our AMS status already MATCHED.
    Please adv asap

  • Shapiro

    Hi Basaria,

    Late penalties for late ISF filings can range from $5,000 for the first infraction to $10,000 for each additional late filing. While CBPs enforcement of late/unfiled entries is still inconsistent, the grace period for penalties has passed.

    If your AMS status is MATCHED, you will have to wait until the shipment arrives if any penalties will be assessed.

  • dziugas

    Hello dear
    I’m later with ISF filling about 4 days, Please advise any steps or company could help to sort this out with min penalty.

  • Shapiro

    Sorry to hear about your late ISF filing.

    We advise that you contact your broker immediately to have them file the ISF, if you have not already done so.

    Unfiled or late filed ISF’s get flagged for hold if not filed properly but at this time, we are unsure if a penalty will occur, but moving forward, we recommend that you make the necessary changes to your supply chain to ensure that your ISFs are filed timely.

    Please let us know if you need anything at all.

  • Grace

    Hi Jane,
    I’m engaged in a NVOCC company, I found out I was a little bit late for filing ISF, the container on board time was 11 Dec. 21:00, but the ISF matched time was 11 Dec. 8:13 a.m., and I got 1y message on 10 Dec.20:57.
    Really anxious about the $5000 penalty will be assessed… Is there any way to know in advance if I’ll be charged? How long will we receive the bill after the US custom decides to make the fine happen? Thank you for your reply.

  • Shapiro

    Good afternoon Grace,

    The actual ruling states that ISF must be filed 48 hours before the shipment is on the final vessel to the U.S. With that in mind, you can email your freight forwarder to confirm if the shipment is transshipping or not, first.

    In addition, you are also only a few hours behind the ‘cut-off’ time so I don’t think your shipment will receive the penalty as it is being assessed against more egregious offenders. Just note that your shipment may receive an examination upon arriving to the U.S.

    We hope this helps and wish you the best of holidays!

  • Richard

    How you doing , , can i do my ISF by myself , and in case is yes ,, i would like to go to any office you guys have to check if i fill it in the write way , thanks i appreciate your help.
    By the way i live in New Jersey and my merchandiser will come by newrr airport,
    best regards

  • Shapiro

    Hi Richard,

    Thanks for reaching out!

    While importers can choose to file their own ISF, it is very important that you understand what information is required so the ISF can be filed correctly and timely. We handle ISF filings for many of our customers, but we cannot offer the service of checking to ensure your ISF is correct.

    We recommend that you enlist the assistance of a customs broker to assist with the filing process if you are unsure about the accuracy.

  • Alaa

    Regarding the late filing penalties , Does it matter if the cargo total value is $1000 or $100,000 ?
    I am filing ISF today and the shipment is leaving today itself.

  • Shapiro

    Hi Alaa,

    We’re sorry to hear about the late ISF filing for your shipment.

    The dollar value of the goods does not matter since any ocean import shipment is required to have the ISF filed 24-72 hours prior to the vessel departure.

    You may not end up with any penalties for the late filing, but we would recommend that you contact your customs broker immediately for more information.

    Thanks for reaching out!

  • shelia

    We have a broker we go thru to submit our ISF forms to customs for matches. If the information we send them on original does not match when they send back to us their copy of ISF sent to customs: ex(ship to party, consolidator or selling party) is this an issue with customs? Doesn’t all the information have to match for the arrival and pick up at port?

  • Shapiro

    Hi Shelia,

    The information that is needed to file ISF properly must match what is listed on the original shipping documents. If the information is incorrect, you may experience issues with exams in the future if it is caught by Customs.

    We recommend that contact your broker and supplier to ensure that the information filed for ISF matches so you remain compliant with Customs.

  • Marian

    For ISF filling, if the information was wrong such as vessel, container no. seal no. so ISF still complete with filling?

  • Shapiro

    Hi Marian,

    Thanks for reaching out to us!

    The information filled for ISF must reflect the correct information on the shipment.

    If there are discrepancies, even though the ISF was filled on time, the probability of the shipment being flagged for exam will be higher.

    We recommend that you work with your supplier and customs broker to ensure the ISF information being filed is correct.