For a DDP ocean shipment to the United States, the Importer Security Filing (ISF), commonly called ISF 10+2, must be submitted by the legally defined ISF Importer or its authorized agent. Most importer-supplied data is due no later than 24 hours before the cargo is loaded aboard the vessel at the foreign port. A DDP sales term does not automatically make the overseas seller the ISF Importer, so the parties must identify the eligible U.S. filing party and approve the data before the carrier's cutoff.
Quick Answer: Who Files ISF 10+2 Under DDP?
The filing can be transmitted by a licensed U.S. customs broker or another authorized electronic filer, but the filing must be made on behalf of the correct ISF Importer. For ordinary U.S.-bound cargo, that is generally the party causing the goods to arrive within the limits of a U.S. port by vessel. In many standard purchase transactions, this is the owner, purchaser, consignee or agent with the qualifying interest described by U.S. Customs and Border Protection (CBP) rules.
DDP allocates delivery costs, risk and import-clearance obligations between seller and buyer. It does not rewrite CBP's definition of the ISF Importer or create U.S. importer eligibility for a foreign seller. The practical solution is to document the contractual DDP responsibility and the customs filing structure separately, then make sure they work together.
Does ISF Apply to Every DDP Shipment?
No. ISF applies to cargo arriving in the United States by ocean vessel. It does not apply to cargo arriving solely by air, truck or rail. The rule covers non-bulk vessel cargo, while special filing formats and exceptions can apply to bulk cargo, break-bulk cargo, transit movements and certain other shipment types.
The sales term is not the trigger. A shipment can require ISF whether it is sold DDP, DAP, FOB, EXW or under another term. Mode of arrival and the legal cargo movement determine the filing requirement. For an overview of how DDP changes the commercial allocation but not government rules, see the meaning of DDP shipping.
The Ten Importer Data Elements
For standard U.S.-bound ISF-10 cargo, the filing draws on ten importer-side data elements. The following table explains the business evidence that should support each item. It is not a substitute for the current CBP technical specification or advice from the filing broker.
When Is ISF Due?
CBP states that the filing is required no later than 24 hours before cargo is loaded on the vessel destined for the United States. Eight importer data elements generally fall under that pre-loading deadline. Container stuffing location and consolidator information may be submitted as early as possible, but no later than 24 hours before the vessel arrives at a U.S. port. Carrier-side vessel stow-plan and container-status-message obligations follow their own schedules.
The regulatory deadline is not a safe operational cutoff. Brokers and forwarders commonly require data earlier so they can validate names, numbers, HTSUS classifications, bill-of-lading references and bond coverage before transmission. For a DDP shipment, put the broker's cutoff in the booking instructions and work backward from the planned vessel loading time—not the estimated arrival date.
- Before booking: identify the proposed ISF Importer, filer and customs bond structure.
- Before cargo handover: collect the ten data elements and supporting commercial records.
- Before the broker's cutoff: reconcile the purchase order, commercial invoice, packing list and booking data.
- Before vessel loading: obtain the ISF acceptance and the filing transaction reference.
- After changes: send corrections promptly when the supplier, routing, stuffing location, consignee or classification changes.
DDP Contract Responsibility vs. CBP Responsibility
Under the ICC DDP rule, the seller normally arranges export and import clearance and bears the agreed costs through delivery at the named destination. U.S. customs law separately determines who may act as importer, who can authorize a broker and who is responsible for accurate filings. Treating those two systems as identical is the main source of ISF confusion.
A workable DDP file should answer four questions in writing: Who is the ISF Importer? Who will be the importer of record for entry? Who authorizes the broker? Who funds duties, fees, bond and filing charges? These roles can sometimes be held by the same entity, but that is a result of the transaction structure—not a consequence of the three letters “DDP.” Read the detailed comparison of importer of record, consignee and customs broker roles before asking a buyer or logistics provider to accept a customs role.
A Pre-Loading ISF Control Workflow
1. Map the transaction parties
List the seller, buyer, manufacturer, exporter, consignee, ship-to site, ISF Importer, importer of record, broker, forwarder, NVOCC and ocean carrier using full legal names. Explain every difference between the sales contract, invoice and transport documents.
2. Validate identifiers and authority
Confirm the importer and consignee identifiers with the party that owns them. Obtain the required broker authorization and verify that the customs bond covers ISF activity. Never assume a forwarder's service quotation includes an eligible importer, bond or power of attorney.
3. Build one controlled data sheet
Create a single version-controlled sheet for the ten ISF data elements, booking number, master and house bill references, vessel, voyage, planned loading date and broker cutoff. Assign one owner to approve changes.
4. Reconcile product and origin data
Match the HTSUS number and country of origin to the commercial entry plan. Give the broker sufficient product detail to evaluate the classification. The DDP commercial invoice checklist provides a practical cross-check for descriptions, values, origin and party names.
5. Confirm acceptance, not just transmission
Ask the filer for the ISF transaction number and acceptance status. A sent email or uploaded spreadsheet is not evidence that CBP accepted the filing. Document any rejection, correction and final acceptance.
6. Control amendments
Routing and commercial data can change after an initial filing. Define who monitors supplier substitutions, split shipments, updated bills of lading, new ship-to locations and classification changes, and who instructs the filer to amend the ISF.
Common ISF Mistakes in DDP Shipping
- Waiting for the vessel to depart: the key deadline is tied to foreign-port loading, so post-departure filing is already late for most elements.
- Assuming the seller is automatically the ISF Importer: DDP is a sales term, not proof of CBP eligibility.
- Treating the freight forwarder as the filer without confirmation: obtain the actual filer's name, authority and acceptance record.
- Using vague product descriptions: “parts,” “samples” or “accessories” may not support an accurate HTSUS determination.
- Confusing origin with loading country: customs origin depends on applicable rules, not the export port.
- Ignoring amendments: an initially accepted filing may still need correction when shipment data changes.
- Separating ISF from entry planning: importer numbers, classification, origin and parties should remain consistent through cargo release and entry summary.
CBP notes that inaccurate, incomplete or untimely filings can lead to enforcement consequences, including liquidated damages, inspections and cargo delay. The commercial impact can also include rolled cargo, storage, demurrage and urgent broker work. Prevention is usually cheaper than repairing the file after loading.
ISF 10+2 Checklist for DDP Ocean Shipments
- Confirm that the shipment will arrive in the United States by ocean vessel.
- Name the legally appropriate ISF Importer and importer of record.
- Confirm the electronic filer, broker authorization and bond coverage.
- Collect all ten importer data elements with supporting records.
- Match seller, buyer, manufacturer, consignee and ship-to identities across documents.
- Validate the HTSUS number and country of origin before the filing cutoff.
- Record the broker's operational cutoff earlier than the CBP deadline.
- Obtain the ISF transaction number and accepted status before vessel loading.
- Monitor and submit amendments when shipment facts change.
- Carry the same controlled data into the DDP customs clearance process.
Frequently Asked Questions
Can the overseas DDP seller file ISF 10+2?
An authorized electronic filer can transmit the ISF, but the filing must identify the correct ISF Importer under CBP rules. A foreign seller should not assume that agreeing to DDP automatically creates that legal status. The seller and U.S. broker must confirm the eligible party, importer number, bond and authority for the specific transaction.
Is ISF required for DDP air freight?
No. ISF 10+2 applies to cargo arriving in the United States by vessel, not to cargo arriving solely by air, truck or rail. Those modes have different advance-data and entry processes.
Who supplies the ISF data?
The information usually comes from several parties: the seller provides transaction data, the factory confirms manufacturer and origin facts, the buyer or importer supplies identifiers, and the forwarder or consolidator provides booking and stuffing details. One controlled coordinator should reconcile the final dataset.
Does an accepted ISF clear the goods through customs?
No. ISF is an advance security filing. Cargo release, entry summary, admissibility, duties and partner-government-agency requirements are separate processes. An accepted ISF does not prove that the later import entry is complete or correct.
Can an ISF be corrected after filing?
Yes, filings can be updated when information changes, subject to CBP rules and system procedures. Send corrected facts to the filer promptly and retain both the original and amended acceptance records.
Authoritative References
This guide is general operational information, not legal or customs advice. Confirm the filing party, deadline, bond and data requirements with a licensed U.S. customs broker for each shipment.