ResourceUS Customs Filing

US import filing: ISF and AMS, who files what and by when

A US-bound ocean shipment needs two separate advance filings before the cargo is laden: the importer's Importer Security Filing (ISF, the '10+2') under 19 CFR Part 149, and the carrier's cargo manifest through the Automated Manifest System (AMS) under 19 CFR 4.7. This guide sets out, as of July 2026 and sourced to the eCFR and US Customs and Border Protection (CBP), which party owns each filing, the deadline each runs on, and what a late or inaccurate ISF costs.

ISF-10 core deadline
24 hours before lading at the foreign port
ISF penalty exposure
$5,000 per violation (CBP)
AMS clock
24-hour rule, 19 CFR 4.7
Who files
Importer files the ISF; carrier or NVOCC files the AMS manifest

The two US ocean import filings, and why they are separate

A US-bound ocean shipment triggers two separate advance filings with CBP, and they are easy to confuse because they share one deadline. They have different owners, different legal bases, and different consequences.

The first is the Importer Security Filing (ISF), the advance security filing commonly called "10+2". It is codified at 19 CFR Part 149, and the ISF Importer, or an authorized agent such as a customs broker or forwarder, submits it in English through a CBP-approved electronic system. The importer is legally responsible for the ISF even when it delegates the filing to an agent.

The second is the carrier's advance cargo manifest, transmitted through the Automated Manifest System (AMS) under 19 CFR 4.7. The vessel carrier files the manifest, and where a non-vessel operating common carrier (NVOCC) meets CBP's conditions it may transmit its own house-level cargo data directly to CBP.

Both filings run on the same clock for ocean cargo: the core ISF elements and the AMS manifest each fall due 24 hours before the cargo is laden aboard the vessel at the foreign port. That shared deadline is the source of the confusion. The ISF is the importer's security filing, carrying the importer's own bond exposure; the AMS manifest is the carrier's or qualifying NVOCC's filing. This guide treats the two as one origin-side documentation workflow while keeping them distinct by who files, on what clock, and what the exposure is. The European Union runs its own advance security filing, the ICS2 ENS, covered in the ENS rejection guide. The dates and figures below are current as of July 2026 and are sourced to the eCFR and CBP.

ISF versus AMS at a glance

Read across each row to see how the two filings differ by owner, legal basis, deadline, and exposure. The one column they share is the ocean deadline.

FilingWhat it isLegal basisWho filesDeadline (ocean)Exposure
ISF (10+2)The importer's advance security filing19 CFR Part 149ISF Importer or its authorized agent (customs broker or forwarder)24 hours before lading (core elements 1 to 8)Importer's bond; $5,000 per violation (CBP)
AMS (24-hour rule)The carrier's advance cargo manifest19 CFR 4.7Vessel carrier, or a qualifying NVOCC for its house-level data24 hours before lading at the foreign portVessel carrier or qualifying NVOCC bears the filing obligation

The ISF-10: the ten elements the importer files

The "10" in "10+2" is the importer's ten data elements, listed at 19 CFR 149.3(a) and set out in the table below. For a standard import shipment, the ISF Importer or its agent files all ten (on the distinction between house and master bills of lading, see HBL versus MBL).

Eight of the ten are due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port: seller, buyer, importer of record number or foreign trade zone applicant identification number, consignee number, manufacturer or supplier, ship-to party, country of origin, and the commodity Harmonized Tariff Schedule of the United States (HTSUS) number.

Two elements carry flexible timing. The container stuffing location and the consolidator (stuffer) may be provided as early as possible, and in no event later than 24 hours before arrival in a United States port, or upon lading at a foreign port that is less than a 24-hour voyage from the closest United States port. These two flexible-timing importer elements are separate from the carrier's two "+2" requirements, which the following section covers.

The ISF-10 elements

The ten elements in regulatory order, from 19 CFR 149.3(a). Elements 1 through 8 are the core elements due 24 hours before lading; elements 9 and 10 carry the flexible timing described above.

#ElementNotes
1SellerCore; due 24 hours before lading
2BuyerCore; due 24 hours before lading
3Importer of record number / Foreign trade zone applicant identification numberCore; due 24 hours before lading
4Consignee number(s)Core; due 24 hours before lading
5Manufacturer (or supplier)Core; due 24 hours before lading
6Ship to partyCore; due 24 hours before lading
7Country of originCore; due 24 hours before lading
8Commodity HTSUS numberCore; due 24 hours before lading
9Container stuffing locationFlexible timing; no later than 24 hours before US arrival
10Consolidator (stuffer)Flexible timing; no later than 24 hours before US arrival

The '+2' and ISF-5: what the '10+2' name actually means

The "+2" in "10+2" is filed by the carrier, and it is the point most often gotten wrong. It is two carrier requirements that sit outside the importer's ten: the vessel stow plan (19 CFR 4.7c) and container status messages, or CSMs (19 CFR 4.7d). The incoming carrier submits the vessel stow plan no later than 48 hours after the vessel departs the last foreign port, or before arrival for voyages under 48 hours. These are the carrier's obligations. They are never two of the importer's ten elements.

The "10+2" name therefore combines the importer's ten elements with the carrier's two, filed by two different parties.

A reduced filing applies to some cargo. For a shipment made up entirely of foreign cargo remaining on board (FROB), or intended for in-bond immediate exportation (IE) or transportation and exportation (T&E), only five elements are required, the ISF-5: booking party, foreign port of unlading, place of delivery, ship-to party, and commodity HTSUS number (19 CFR 149.3(b)).

AMS and the 24-hour rule: the manifest side

AMS is the manifest side of the same origin-side moment. For US-bound ocean cargo, CBP must receive the electronic equivalent of the vessel's Cargo Declaration (CBP Form 1302) 24 hours before the cargo is laden aboard the vessel at the foreign port, transmitted through the Automated Manifest System or another CBP-approved electronic data interchange system. This is the 24-hour rule, codified at 19 CFR 4.7(b).

The vessel carrier files the manifest. Where an NVOCC delivers cargo to the vessel carrier for lading at the foreign port and meets CBP's conditions, the NVOCC may transmit its own house-level cargo data directly to CBP through the vessel AMS system, received 24 or more hours before the cargo is laden at the foreign port. An NVOCC that does not self-file discloses the data to the vessel carrier to file.

The 24-hours-before-lading requirement carries a bulk and break-bulk exemption. Carriers of bulk cargo, and carriers of break-bulk cargo to the extent provided in 19 CFR 4.7(b)(4)(ii), are exempt with respect only to that cargo; for those voyages CBP must instead receive the electronic cargo declaration 24 hours before the vessel arrives in the United States.

Per-carrier manifest specifics, such as advance-manifest windows and surcharges, sit on the carrier documentation pages and the documentation handling page rather than here. For two worked examples, see the COSCO documentation and Evergreen documentation pages.

What a late or inaccurate ISF costs

CBP may assess liquidated damages against the ISF Importer through its bond: $5,000 per late ISF, $5,000 per inaccurate ISF, and $5,000 for the first inaccurate ISF update, per the CBP ISF FAQ (2023) and CBP Decision 09-26. Separately, the ISF Importer must obligate a bond to file. A stand-alone Appendix D ISF bond is $10,000 for a single transaction, and the continuous bond minimum is $50,000. Those figures are bond amounts and apply as a customs bond requirement, separate from the per-violation penalty above.

Where Expedion fits (the manifest side)

Expedion is a managed AI workforce for freight forwarding operations. Expedion agents prepare and validate the data that feeds each AMS filing and track it against the 24-hour clock, surfacing discrepancies to the forwarder's reviewer before the data reaches the filer. The filing itself is transmitted by the responsible filer: the vessel carrier for the master manifest, or the NVOCC where it self-files house-level data with CBP. The ISF is the importer's own security filing and stays with the importer and its broker; Expedion's surface on this page is the carrier-side manifest data only. This capability runs on top of your existing systems through the CargoWise integration and the documentation workflow, and is in supervised production with design partners, not general availability.

Prepare and validate the manifest data

Agents assemble and check the cargo data that feeds the AMS filing, so gaps and mismatches are caught before the data reaches the filer.

Track the 24-hour clock

Agents track each shipment against the 24-hours-before-lading deadline and surface anything at risk to the forwarder's reviewer while there is still time to act.

Hand off to the responsible filer

The filing itself is transmitted by the responsible filer, the vessel carrier for the master manifest or the NVOCC for its own house-level data. Expedion prepares and validates the data; the ISF and any customs entry stay with the importer and its broker.

Frequently asked questions

Is ISF the same as AMS?

No. They are two separate advance filings for US-bound ocean cargo. The Importer Security Filing (ISF, or 10+2) is the importer's advance security filing under 19 CFR Part 149, filed by the importer or its agent. AMS is the Automated Manifest System the vessel carrier, or a qualifying NVOCC, uses for the advance cargo manifest under 19 CFR 4.7. They share the 24-hours-before-lading deadline for ocean cargo but have different filers, legal bases, and exposure.

Who is responsible for filing the ISF?

The ISF Importer is legally responsible for the ISF, defined at 19 CFR 149.1. The importer may delegate the actual filing to an authorized agent, such as a customs broker or forwarder, but the legal responsibility stays with the importer even when the filing is delegated.

When is the ISF due?

For ocean cargo, eight of the ten ISF elements are due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port. Two elements, the container stuffing location and the consolidator, carry flexible timing and may be provided later, no later than 24 hours before the cargo arrives in a United States port.

What does the '+2' in 10+2 mean?

The 10 is the importer's ten data elements. The +2 is two additional requirements filed by the carrier, not the importer: the vessel stow plan and container status messages. A common error is to fold the stow plan or container status messages into the importer's ten elements; they are the carrier's separate obligations.

What happens if the ISF is filed late?

CBP may assess liquidated damages against the ISF Importer of $5,000 per violation, including $5,000 for a late ISF, $5,000 for an inaccurate ISF, and $5,000 for the first inaccurate ISF update, per the CBP ISF FAQ and CBP Decision 09-26. The importer must also obligate a bond to file.

Does Expedion file my ISF?

No. The ISF is the importer's security filing and stays with the importer and its broker. Expedion's surface here is the carrier-side manifest data: its agents prepare and validate the data that feeds the AMS filing and track it against the 24-hour clock, while the filing itself is transmitted by the responsible filer, the vessel carrier or the self-filing NVOCC. This carrier-side capability is in supervised production with design partners today.

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