July 11, 2016 | Industry Insights, ISF

Important Changes to ISF Regulations, Proposed Rule

Share This:
Featured Image

The “interim final” rule that became effective on January, 26, 2009 has now – for practical purposes – become the final rule as to a great many ISF filings. However, for some time CBP and the trade have been discussing an urgent need for limited changes to Part 149 of the Customs Regulations, primarily to eliminate confusion as to ISF-5* and certain other filing responsibilities. The result has been the publication of a notice of proposed rulemaking in the July 6 Federal Register. The comment period expires on September 6, 2016.

CBP has addressed the situation by drafting a new definition of “ISF Importer” – revised 19 C.F.R. § 149.1(a) – which reads as follows:

“For purposes of this part, Importer Security Filing Importer (ISF Importer) means the party causing goods to arrive within the limits of a port in the United States by vessel. For shipments other than foreign cargo remaining on board (FROB), the ISF Importer will be the goods’ owner, purchaser, consignee, or agent such as a licensed customs broker. For IE and T&E in-bond shipments, and goods to be delivered to an FTZ, the ISF Importer may also be the party filing the IE, T&E, or FTZ documentation. For FROB cargo, the ISF Importer will be the carrier or the non-vessel operating common carrier.”

We are urging all of our friends in the customs brokerage, freight forwarding, and NVOCC community to:

  • Read the proposed rule carefully
  • Be in communication with your local and national trade associations to articulate your concerns and gain additional perspective
  • Consider submitting comments of your own directly to CBP
  • Take note of the fact that the proposed change could impose new ISF responsibilities upon NVOCCs in connection with FROB

Most of all, we are urging you to carefully consider the ISF-related liability implications when filing ISFs or in-bond documents or when issuing house bills of lading on goods coming to the U.S. via ocean.

*Note that FTZ shipments require an ISF-10.

Share This:


Thank You to Karen Groff

We have important news to share with you. Karen Groff, President of Roanoke Insurance Group, has decided to leave the organization. Although our hearts are heavy with this news, we respect her decision and wish her all the best in her future endeavors. Karen played an integral role in Roanoke’s success over the past 30 […]

Corporate Communiqué, Industry Insights

Cargo Theft Holiday Advisory – Preparations to Secure Your Supply Chain

Cargo thieves are poised to strike as you look forward to relaxing by the lake or beach during the upcoming Memorial Day weekend. Cargo theft increases during extended holiday weekends because cargo is typically left unattended for longer periods. However, you can stay ahead of these opportunistic thieves and reduce exposure by following these best […]

Cargo Insurance, Industry Insights

We are pleased to announce Karen Rzeszutko has been named President of Roanoke Insurance Group, effective August 1, 2023!

Karen has been a part of Roanoke for nearly 20 years. During this time, she has shown exceptional leadership skills and technical expertise in multiple customer-facing positions, such as Head of Marine & Liability Underwriting and Head of Liability Claims. Her most recent role was SVP, Chief Underwriting Officer, Marine at Munich Re Specialty Group […]

Industry Insights

Sign up for our latest articles and events.

Roanoke is the leading provider of insurance and surety solutions for transportation and logistics providers. In fact, we are recognized as the most reliable source for U.S. customs bonds.


If you have any questions or need help, feel free to contact with our team.



1501 E. Woodfield Road

Suite 400W

Schaumburg, IL 60173


390 Bay Street

Munich Re Centre, 22nd Floor

Toronto, ON M5H 2Y2

Solutions that Go the Distance.

© 2021 Roanoke Insurance Group Inc. A Munich Re company

Better Business Bureau logoCoverholder at Lloyd's logo