Short answer: if your FBA inventory travels to the United States by ocean, someone has to send CBP an Importer Security Filing (ISF, also called “10+2”) before the container is loaded at the origin port. The legally responsible party is the “ISF Importer” — usually you, the brand owner buying the goods — even when a freight forwarder or customs broker presses the button. Eight of the ten data elements are due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port, and CBP’s mitigation guidelines allow a $5,000 liquidated damages claim per late ISF (CBP ISF FAQ, May 2023 edition, checked 2026-10-05). Air and express shipments are outside the rule.
This guide treats ISF filing for Amazon FBA as a standalone task. The wider ocean workflow lives in our China-to-FBA shipping guide, and duty math in the import tariffs framework.
What the Importer Security Filing 10+2 is and which shipments it covers
The Importer Security Filing is an advance cargo security filing, not a customs entry and not a duty payment. CBP’s program page states: “On January 26, 2009, the new rule titled Importer Security Filing and Additional Carrier Requirements (commonly known as ‘10+2’) went into effect. This rule applies to import cargo arriving to the United States by vessel.” (CBP ISF page, last modified Jul 28, 2023, checked 2026-10-05). Full enforcement began on January 26, 2010, per CBP’s FAQ.
The “10” is the ten data elements the ISF Importer files. The “+2” is two carrier obligations: vessel stow plans and container status messages.
Three scope points matter for Amazon sellers:
- Ocean only. 19 CFR 149.2(a) opens with “For cargo arriving by vessel”. Air freight and courier parcels do not trigger an ISF.
- FCL and LCL alike. Elements are filed “at the lowest bill of lading level (i.e., at the house bill of lading level, if applicable)” under 19 CFR 149.3(a), so a consolidated LCL shipment still needs an ISF tied to your house bill.
- Transit cargo is different. Goods moving through the US in-bond or staying on board file a shorter “ISF-5” instead.
Who files the ISF for an Amazon FBA shipment
19 CFR 149.1(a) defines the ISF Importer as “the party causing goods to arrive within the limits of a port in the United States by vessel.” For ordinary imports that party “will be the goods’ owner, purchaser, consignee, or agent such as a licensed customs broker” (2018 amended definition, quoted in the CBP ISF FAQ, checked 2026-10-05).
In a typical private label setup you buy finished goods from a factory, own them on the water, and are named as importer of record. That makes you the ISF Importer. What you outsource is the transmission, not the responsibility:
| Question | CBP ISF FAQ (May 2023) | For an FBA seller |
|---|---|---|
| Must the filer be a customs broker? | “A filing agent does not have to be a customs broker except for the case of a Unified Entry filing.” | Your forwarder can file. |
| Can an overseas forwarder file? | “A foreign freight forwarder can also be a filing agent.” | Origin-side filing is allowed. |
| Can a foreign company be the ISF Importer? | “Yes, but a U.S. entity must be provided for the consignee element.” | Non-US sellers still need a US consignee number. |
| Who is liable for agent errors? | “the ISF Importer is ultimately responsible for the timely, accurate, and complete submission of the ISF” | The claim lands on you. |
DDP shipments are the exception. Where a foreign seller ships DDP and acts as US importer of record, CBP’s FAQ says “they would typically be the ISF Importer as well since they are causing the goods to arrive in the U.S. and have the best access to the ISF-10 data elements”, and the liquidated damages claim would go to that foreign importer of record. Settle who is importer of record before booking; our freight forwarder guide lists ISF filing as a destination-side quote line to confirm.
The 10 ISF data elements, explained for FBA sellers
All ten elements come from 19 CFR 149.3(a). Manufacturer, country of origin and HTSUS number must be linked at the line-item level, so a mixed-SKU container needs each product line matched correctly.
| # | Element | Where FBA sellers usually get it | Due |
|---|---|---|---|
| 1 | Seller | Supplier that sold you the goods, as on the commercial invoice | 24h before lading |
| 2 | Buyer | Your company | 24h before lading |
| 3 | Importer of record number | Your EIN or CBP-assigned number | 24h before lading |
| 4 | Consignee number | Number of the US party on whose account goods ship, usually your EIN | 24h before lading |
| 5 | Manufacturer (or supplier) | Entity that last made or assembled the goods — the factory, not only the trading company | 24h before lading |
| 6 | Ship to party | First party to physically receive goods after customs release: forwarder warehouse, or the Amazon fulfillment center if the container goes direct | 24h before lading |
| 7 | Country of origin | Where the goods were made under US rules, not the sailing port | 24h before lading |
| 8 | Commodity HTSUS number | Your HTS code, at least 6 digits | 24h before lading |
| 9 | Container stuffing location | Address where goods were stuffed into the container | 24h before US arrival |
| 10 | Consolidator (stuffer) | Party who stuffed or arranged stuffing | 24h before US arrival |
Two practical notes. For the ship-to party, CBP’s FAQ wants “the actual deliver to name/address; not the corporate address”, and accepts a warehouse FIRMS code if the exact address is unknown at filing. For the HTSUS number, six digits satisfy the ISF, but the code only doubles as the entry code at 10 digits — another reason to fix classification early, as covered in the tariffs guide.
The ISF deadline: 24 hours before vessel loading
19 CFR 149.2(b) sets two clocks. Elements 1 to 8 are due “no later than 24 hours before the cargo is laden aboard the vessel at the foreign port.” Elements 9 and 10 are due “as early as possible, in no event later than 24 hours prior to arrival in a United States port” (73 FR 71730 rule text, checked 2026-10-05).
The first clock is the one that bites. It is tied to loading at the origin port, so the vessel schedule sets it — not your purchase order and not the arrival date. Working backwards:
- At PO stage — confirm HTS code, importer of record and who files.
- Before cargo-ready date — send the filer elements 1 to 8 per product line.
- At least 24 hours before loading — ISF transmitted; get the transaction number.
- At least 24 hours before US arrival — stuffing location and consolidator added, all updates done.
The bill of lading is a separate trap. CBP’s FAQ states: “The ISF must match to the bill of lading at least 24 hours prior to arrival at the first U.S. Port.”
For elements 5 to 8, 19 CFR 149.2(f) allows an initial range based on best available data, updated no later than 24 hours before US arrival. Under 149.2(d) you must update the filing whenever information changes before the goods reach a US port; under 149.2(e) you must withdraw it if the goods will no longer be imported.
ISF bonds: what secures the filing
Every standard ISF must obligate a CBP bond — one of five continuous bond types (activity codes 1, 2, 3, 4 or 16) or a single transaction bond — which “must be on-file in ACE eBond to secure the ISF” (CBP ISF FAQ).
- Your continuous import bond. An existing activity code 1 bond can secure your ISF; CBP says riders are unnecessary because activity 1 to 4 bonds already contain the ISF obligation.
- A single transaction bond. Where CBP requires collateral, it is the full face amount: “$10,000 for each ISF Single Transaction Bond or $50,000 for the minimum continuous bond for each annual period” (CBP ISF FAQ, checked 2026-10-05).
- Your filer’s bond. The filer can obligate its own bond, but then agrees to have it charged for breaches, so expect that risk to be priced in.
The May 2023 FAQ lets informal shipments valued under $2,500 file as ISF Type 11 without a bond. It predates the suspension of the $800 de minimis exemption described in our tariffs guide, so do not rely on its Section 321 sub-code today.
What happens if the ISF is late, wrong or missing
CBP’s program page says failure to comply “could ultimately result in monetary penalties, increased inspections and delay of cargo.” The FAQ makes each part concrete:
- Liquidated damages. Under mitigation guidelines published July 17, 2009, CBP “may assess a claim for liquidated damages as follows: $5,000 per late ISF, $5,000 per inaccurate ISF, and $5,000 for the first inaccurate ISF update.” Claims can be cancelled in full if issued in error or through no fault of the ISF Importer.
- Holds and exams. “Non-compliant ISF Importers should expect to experience delays in the release of their cargo while CBP analyzes and potentially examines the cargo”. A first-time importer whose cargo arrives with no ISF faces “an ISF Cargo Hold and non-intrusive inspection (NII), or full inspection if deemed necessary.”
- Long tail. The statute of limitations for ISF liquidated damages is “six years from the date of the breach of the bond.”
- No bond is not no exposure. Without a bond, the ISF Importer “may also be subject to penalties for violative behavior up to the value of the cargo in accordance with 19 U.S.C. 1595a(b).”
For FBA sellers the bigger cost is usually the hold: exam fees, port storage and a missed Amazon delivery appointment compound fast. And don’t delete and re-file while goods are on the water — the FAQ warns this “will expose the ISF Importer to liquidated damages for a late filing.” Update the original instead.
CBP notes its FAQ answers “are for informational purposes only and are non-binding”; 19 CFR Part 149 is the binding text.
Pre-booking ISF checklist for FBA sellers
- Ocean shipment confirmed (air and express need no ISF)
- ISF Importer named in writing — you, or a DDP supplier acting as importer of record
- Filing agent chosen, and who pays if their error triggers a claim
- Bond confirmed: continuous, single transaction, or the filer’s
- EIN or CBP-assigned number ready
- Real factory name and address, not only the trading company
- HTS code per product line, linked to manufacturer and origin
- Ship-to party decided: forwarder warehouse or Amazon fulfillment center
- Origin loading cutoff known, ISF due 24 hours before it
- ISF transaction number requested from the agent
Still choosing partners? Compare what Amazon Freight and Amazon Global Logistics each cover, and confirm whether your sourcing agent will collect factory data for the filing.
Frequently Asked Questions
Can my freight forwarder file the ISF for me?
Yes. CBP’s FAQ says a filing agent need not be a customs broker except for Unified Entry filings, and a foreign freight forwarder can be a filing agent. You remain responsible as ISF Importer, so ask for the filing confirmation.
How far in advance do I have to file the ISF?
Eight elements are due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port; stuffing location and consolidator no later than 24 hours before US arrival (19 CFR 149.2(b), checked 2026-10-05).
What is the penalty for a late ISF?
CBP’s mitigation guidelines allow $5,000 per late ISF, $5,000 per inaccurate ISF and $5,000 for the first inaccurate update (CBP ISF FAQ, May 2023 edition, checked 2026-10-05). Cargo holds and inspections can follow.
Does Amazon file the ISF for FBA shipments?
Amazon is not named in CBP’s ISF rule or FAQ. The ISF Importer is the party causing the goods to arrive by vessel — for most FBA sellers, the seller or its agent — so plan the filing yourself unless a contract says otherwise.
Conclusion
ISF is a small filing with a hard deadline. Decide who the ISF Importer is, line up a bond and a filing agent, and collect factory, HTS and ship-to data at purchase-order stage. Treat the 24-hours-before-loading cutoff as the last moment those facts can change, and update rather than re-file if they do.