ISF 10+2 for charcoal shipments: which data you need, who holds it, and the three deadlines
By Mohamad Sinno, Charcoal Expert · Reviewed by Budi Hartanto, shipping specialist · Last updated
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"File 24 hours before loading" is right for eight of the ten elements and wrong for two. 19 CFR 149.2(b) splits the filing across three deadlines, and the last pair — container stuffing location and consolidator — runs to 24 hours before arrival in a US port, not before lading. Four elements sit on the factory side of the table and are the ones worth chasing early.
The three deadlines, as the regulation writes them
| Tier | Elements | Deadline | Relief available? |
|---|---|---|---|
| §149.2(b)(1) | Seller · Buyer · IOR number · Consignee number(s) | ≥24 h before lading at the foreign port | No |
| §149.2(b)(2) | Manufacturer (or supplier) · Ship-to party · Country of origin · HTSUS number | ≥24 h before lading at the foreign port | Yes — §149.2(f) best-available-data |
| §149.2(b)(3) | Container stuffing location · Consolidator (stuffer) | As early as possible; ≥24 h before arrival in a US port | n/a — already an arrival-clock element |
The middle row is the one that makes a first shipment workable. Under §149.2(f) those four elements may be filed on "the best available data available at the time", then updated "as soon as more precise or more accurate information is available", in no event later than 24 hours before arrival. So a supplier detail that is not final at lading does not have to hold the filing — but §149.2(d) makes the update mandatory, not optional.
The data-element table: who actually holds each one
CBP requires the ISF Importer to file all ten; it does not divide the work. The split below is an allocation — reasoning from each element's own definition in §149.3(a) about where the information lives. It is the handoff list to send your supplier.
| # | Element (§149.3(a)) | Who holds it | Note |
|---|---|---|---|
| 1 | Seller | Both | Last known entity selling the goods; on your contract |
| 2 | Buyer | Importer | — |
| 3 | Importer of record number | Importer | IRS/EIN/SSN or CBP-assigned number |
| 4 | Consignee number(s) | Importer | — |
| 5 | Manufacturer (or supplier) | Factory | Name + address of who produces the goods |
| 6 | Ship-to party | Importer | First deliver-to party after customs release |
| 7 | Country of origin | Factory | Country of manufacture, production or growth |
| 8 | Commodity HTSUS number | Broker | 6-digit minimum; usable for entry only at 10-digit from the IOR or its licensed broker |
| 9 | Container stuffing location | Factory | Physical address where goods were stuffed |
| 10 | Consolidator (stuffer) | Factory | Who stuffed the container, or arranged it |
One structural rule is easy to miss: §149.3(a) requires that "the manufacturer (or supplier), country of origin, and commodity HTSUS number must be linked to one another at the line item level". They are not three free-standing fields. If a container mixes shapes or grades declared under different lines, each line carries its own trio — which is where the 4402.20 versus 4402.90 question stops being academic.
Where you genuinely cannot verify what a supplier tells you, §149.2(c) is explicit: CBP "will permit the party to electronically present the information on the basis of what the party reasonably believes to be true". That is a standard of good faith, not a licence to guess — and it does not survive an update duty you ignored.
The "+2" is the carrier's, and it is not in Part 149
The two carrier filings live in a different part of the regulations from your ten, and run on a different clock. The vessel stow plan (19 CFR 4.7c) is due no later than 48 hours after the vessel departs the last foreign port, and its container fields include a hazmat code where one applies — which, for a UN 1361 Class 4.2 charcoal booking, it does. Container status messages (19 CFR 4.7d) cover nine events from booking confirmation to gate-in and gate-out, but only "if the carrier creates or collects" that message already; the rule adds no duty to instrument what a carrier does not track.
Worth knowing precisely because it is not your filing. Section 149.3(b), sometimes cited as the carrier pair, is nothing of the kind — it is the reduced five-element set for cargo remaining on board or moving in-bond for export. The ISF is one US filing among several, and entry, duty status and the three agencies that touch a charcoal import are covered in importing shisha charcoal to the USA.
Timing and penalty avoidance
The $5,000 figure everyone quotes is not a statutory fine. It is a bond condition: Appendix D to 19 CFR Part 113 binds principal and surety to "pay liquidated damages of $5,000 for each violation, or such other amount as may be authorized by law or regulation upon demand by CBP". That is why an ISF and a bond are one subject — the exposure runs against the bond you posted, as a continuous bond or a single-transaction ISF bond. CBP states separately that non-compliance "could ultimately result in monetary penalties, increased inspections and delay of cargo"; on a first entry the inspection and delay usually cost more than the damages.
- Confirm bond coverage before the booking, not at the quay. Without it there is nothing to file against.
- Send your supplier the four factory-side elements as a written request at booking confirmation — elements 5, 7, 9 and 10.
- File tiers (b)(1) and (b)(2) at least 24 hours before lading, using §149.2(f) best-available-data for the four elements that allow it rather than missing the deadline.
- File stuffing location and consolidator as soon as the container is packed, and in any case 24 hours before arrival.
- Update under §149.2(d) whenever better information lands, and withdraw under §149.2(e) if the goods stop being US-bound. Both are obligations, not courtesies.
Sending a first US container? Message us on WhatsApp at +62 821 3924 038 and we will return elements 5, 7, 9 and 10 in writing, in the form your broker files them.
Sources, all read 10 August 2026: eCFR 19 CFR 149.2, 149.3, 4.7c, 4.7d and Appendix D to Part 113 (Title 19 current as of 6 Aug 2026, last amended 24 Jul 2026); U.S. Customs and Border Protection, "Importer Security Filing '10+2'" (mod. 28 Jul 2023). This is import guidance, not legal advice — the ISF Importer certifies the filing.