Importer Security Filing (ISF 10+2) is a mandatory U.S. Customs and Border Protection (CBP) security requirement for ocean cargo entering the United States. Before goods are loaded onto a vessel bound for the U.S., importers and ocean carriers must electronically submit shipment information to CBP for security screening and risk assessment.

ISF was introduced to strengthen supply chain security by allowing CBP to identify high-risk shipments before they depart from foreign ports. While customs brokers often file ISF on behalf of importers, the legal responsibility for filing accurate and timely information ultimately rests with the importer.

This guide explains everything you need to know about ISF 10+2, including filing requirements, deadlines, required data elements, exemptions, penalties, and best practices for maintaining compliance.

ISF 10+2 Is a Mandatory Security Filing for Ocean Imports

Importer Security Filing (ISF), commonly referred to as ISF 10+2, is a pre-arrival security filing required by U.S. Customs and Border Protection (CBP) for cargo imported into the United States by ocean vessel.

The filing provides CBP with advance information about imported goods before they are loaded overseas, allowing the agency to assess security risks and target potentially dangerous shipments before they reach U.S. ports.

ISF applies only to ocean freight. It does not apply to shipments arriving by air, truck, or rail.

Importer Security Filing (ISF)

An electronic filing submitted to CBP before cargo is loaded onto an ocean vessel destined for the United States. Importers provide ten data elements while ocean carriers provide two additional data elements.

U.S. Customs and Border Protection (CBP)

The federal agency responsible for securing U.S. borders, facilitating lawful international trade, collecting customs duties, and enforcing import regulations.

Ocean Carrier

A shipping company that transports containers by sea. Ocean carriers are responsible for submitting two carrier-specific data elements as part of the ISF 10+2 requirement.

Importer of Record (IOR)

The individual or business legally responsible for ensuring imported goods comply with U.S. customs laws, including ISF compliance, customs entry, duty payment, and recordkeeping.

What Does “10+2” Mean?

The name 10+2 refers to the total number of data elements required before an ocean shipment arrives in the United States.

Together, these filings provide CBP with the information needed to perform advance cargo risk assessments before containers are loaded onto vessels.

Although the importer and carrier submit different information, both filings work together to support supply chain security and facilitate legitimate trade.

Why ISF Was Introduced

Following the events of September 11, 2001, the United States implemented several initiatives to strengthen cargo security and identify potential threats before shipments reached U.S. ports.

Importer Security Filing became one of the key programs designed to enhance visibility into international supply chains by requiring shipment information before cargo is loaded overseas.

Today, ISF helps CBP:

Rather than delaying inspections until goods arrive in the United States, CBP can evaluate shipment data well before vessels begin their voyage.

Who Must File ISF?

ISF generally applies to the Importer of Record (IOR) or the party responsible for bringing commercial goods into the United States.

Although importers often authorize licensed customs brokers to submit ISF electronically, legal responsibility remains with the importer.

Parties commonly involved include:

Working with a customs broker simplifies the filing process, but importers should verify that all submitted information is accurate and complete.

Which Shipments Require ISF?

ISF is required for most commercial cargo transported to the United States by ocean vessel.

Typical shipments requiring ISF include:

Whether goods are shipped in a single container or consolidated with other importers’ cargo, ISF generally applies when transportation is by ocean.

Which Shipments Are Exempt?

Not every shipment entering the United States requires an Importer Security Filing.

Common exemptions include:

Although these shipments are exempt from ISF, they remain subject to other applicable CBP reporting and customs requirements.

The importer portion of ISF consists of ten required data elements that describe the shipment, the parties involved, and the imported merchandise.

Accurate information is essential because errors or omissions may result in shipment delays, cargo examinations, or monetary penalties.

The required importer data elements are:

  1. Manufacturer (or Supplier)
  2. Seller
  3. Buyer
  4. Ship To Party
  5. Container Stuffing Location
  6. Consolidator (Stuffer)
  7. Importer of Record Number
  8. Consignee Number
  9. Country of Origin
  10. Harmonized Tariff Schedule (HTSUS) Number

Each of these elements helps CBP understand where goods originate, who is responsible for them, and how they should be classified under U.S. customs regulations.

The 10 Importer Data Elements Explained

1. Manufacturer (or Supplier)

This identifies the company that manufactured, produced, assembled, or supplied the imported goods.

Providing the correct manufacturer information helps CBP trace products back to their source and assess potential security risks.

2. Seller

The seller is the last known entity that sold the goods before they were exported to the United States.

This information helps establish the commercial transaction behind the shipment.

3. Buyer

The buyer is the individual or business purchasing the goods for import into the United States.

In many cases, the buyer is also the Importer of Record.

4. Ship To Party

This identifies the first physical delivery location within the United States where the imported goods are intended to arrive after customs clearance.

The ship-to location may differ from the buyer’s business address.

5. Container Stuffing Location

This refers to the physical location where cargo was loaded into the shipping container.

Knowing where containers were packed helps CBP perform more accurate cargo risk assessments.

6. Consolidator (Stuffer)

The consolidator is the company responsible for loading multiple shipments into a container or arranging the cargo for export.

For Less than Container Load (LCL) shipments, this is often a freight consolidator.

7. Importer of Record Number

This is typically the importer’s IRS Employer Identification Number (EIN), Social Security Number (SSN), or CBP-assigned importer number.

It identifies the party legally responsible for the import transaction.

8. Consignee Number

The consignee is the party receiving the imported goods in the United States.

In many cases, this information matches the Importer of Record, although it may differ depending on the transaction.

9. Country of Origin

The country of origin identifies where the goods were manufactured or substantially transformed.

This information affects duty rates, admissibility requirements, trade agreements, and regulatory compliance.

10. Harmonized Tariff Schedule (HTSUS) Number

The HTSUS classification identifies the imported product under the Harmonized Tariff Schedule of the United States.

Correct classification is critical because it determines applicable duties, trade measures, and regulatory requirements.

The 2 Carrier Data Elements

Unlike the importer’s ten data elements, the final two elements are submitted directly by the ocean carrier.

These include:

Vessel Stow Plan

A detailed electronic map showing where every container is positioned aboard the vessel.

This information helps CBP identify container locations during inspections and evaluate cargo security risks.

Container Status Messages (CSMs)

Electronic messages generated throughout the shipping process that track significant container movements and events, such as loading, unloading, gate movements, and transfers.

CSMs provide CBP with greater visibility into the movement of containers before they arrive in the United States.

Although carriers are responsible for submitting these two elements, importers should understand how they fit into the overall ISF 10+2 program and why timely communication with shipping partners is essential.

When Must ISF Be Filed?

Timing is one of the most important aspects of Importer Security Filing compliance.

For most ocean shipments, the importer’s ISF must be submitted at least 24 hours before the cargo is loaded onto the vessel at the foreign port of departure. This is commonly known as the 24-hour rule.

Waiting until the vessel has departed is too late. Late or missing filings may result in shipment delays, cargo examinations, and financial penalties.

Whenever possible, importers should submit ISF as soon as sufficient shipment information becomes available rather than waiting until the last minute.

Understanding the 24-Hour Rule

The 24-hour rule requires ISF information to reach U.S. Customs and Border Protection (CBP) before cargo is loaded onto an ocean vessel destined for the United States.

For example:

Submitting early provides time to correct validation errors and reduces the risk of compliance issues.

Why Early Filing Is Recommended

Many importers mistakenly wait until the shipment is ready to depart before gathering ISF information.

Instead, importers should begin collecting the required data as soon as a purchase order is confirmed.

Early filing provides several advantages:

For regular importers, incorporating ISF into the purchasing process rather than the shipping process can significantly improve compliance.

Who Can File an ISF?

Although the importer is legally responsible for ISF compliance, the filing itself may be submitted by an authorized party.

Common filing parties include:

Regardless of who files the ISF, the importer remains responsible for ensuring the information submitted to CBP is complete and accurate.

Filing Through a Licensed Customs Broker

Most importers authorize a licensed customs broker to prepare and submit the ISF electronically through CBP’s Automated Broker Interface (ABI).

This simplifies the filing process because brokers already have access to CBP systems and understand import documentation requirements.

However, brokers rely entirely on the information provided by suppliers, freight forwarders, and importers. Incorrect information supplied to the broker may still expose the importer to penalties.

Power of Attorney (POA)

Before a customs broker can file an ISF on your behalf, they generally require a valid Power of Attorney (POA).

A POA authorizes the broker to act as your representative when communicating with CBP and submitting customs documentation.

Without a valid authorization, the broker cannot legally file your ISF.

ISF Bond Requirements

Many first-time importers are surprised to learn that ISF filings are generally supported by a customs bond.

A customs bond guarantees payment of duties, taxes, fees, and certain compliance obligations owed to CBP.

Depending on your importing activity, you may use either:

The right option depends on how frequently you import goods into the United States.

Single Entry Bond (SEB)

A Single Entry Bond covers one specific shipment.

It is often suitable for businesses importing occasionally or making one-time purchases.

Each shipment requires its own bond.

Continuous Bond

A Continuous Bond remains active for twelve months and covers unlimited imports during that period.

Businesses importing regularly often choose a Continuous Bond because it is generally more cost-effective and simplifies customs compliance.

Many frequent importers also use a Continuous Bond to avoid arranging a separate bond for every shipment.

ISF vs. Customs Entry

Although they are closely related, ISF and Customs Entry serve different purposes.

FeatureISF 10+2Customs Entry
PurposeSecurity screeningCustoms clearance
Filed BeforeCargo loading overseasCargo arrival in the U.S.
Submitted ToCBPCBP
Applies ToOcean imports onlyMost commercial imports
Main FocusSupply chain securityDuty assessment and cargo release

An ISF filing does not replace a Customs Entry.

Importers typically need both to legally import commercial goods into the United States.

What Is ISF-5?

Not every ocean shipment requires the standard ISF 10 filing.

Certain shipments moving through the United States without entering U.S. commerce use a simplified filing known as ISF-5.

Examples include:

Because these shipments are not intended for U.S. consumption, fewer data elements are required.

Can an ISF Be Amended?

Yes, in many situations, shipment information changes after the initial ISF has been submitted.

Common updates include:

Importers should update the filing as soon as corrected information becomes available.

Keeping ISF information current demonstrates good-faith compliance and helps reduce potential enforcement issues.

ISF Penalties

Failure to comply with ISF requirements can result in significant consequences.

Potential violations include:

CBP may assess liquidated damages of up to $5,000 per violation.

In addition to monetary penalties, importers may experience:

Maintaining accurate records and filing on time remains the best way to avoid enforcement actions.

Common ISF Filing Mistakes

Many ISF penalties result from preventable errors rather than intentional violations.

Common mistakes include:

Establishing a standardized document collection process with overseas suppliers can significantly reduce these errors.

Best Practices for ISF Compliance

Successful importers treat ISF as an integral part of their supply chain rather than a last-minute customs requirement.

Recommended best practices include:

A proactive compliance process helps reduce delays, avoid penalties, and improve supply chain efficiency.

Frequently Asked Questions

What is ISF 10+2?

ISF 10+2 is a U.S. Customs and Border Protection security filing required for most commercial ocean shipments entering the United States. Importers submit ten data elements, while ocean carriers submit two additional data elements before cargo is loaded overseas.

Who files the ISF?

The importer is legally responsible for the filing, although licensed customs brokers or authorized agents commonly submit it on the importer’s behalf.

When is ISF due?

For most shipments, ISF must be filed at least 24 hours before cargo is loaded onto the vessel at the foreign port.

Is ISF required for air freight?

No. ISF applies only to ocean cargo. Air, truck, and rail shipments follow different CBP reporting requirements.

What is an ISF bond?

An ISF bond is generally provided through a customs bond, such as a Single Entry Bond or Continuous Bond, which guarantees compliance with CBP requirements.

What is ISF-5?

ISF-5 is a simplified filing used for certain in-bond shipments, including Freight Remaining on Board (FROB), Immediate Exportation (IE), and Transportation and Exportation (T&E).

Can I amend an ISF after filing?

Yes. If shipment information changes after submission, importers should update the filing as soon as accurate information becomes available.

What happens if ISF is filed late?

Late filings may result in cargo delays, customs examinations, and liquidated damages of up to $5,000 per violation.

Does ISF replace Customs Entry?

No. ISF is a security filing submitted before loading, while Customs Entry is used to clear imported goods and assess duties after arrival.

Does my customs broker handle everything?

Customs brokers often prepare and submit ISF filings, but the importer remains legally responsible for the accuracy and timeliness of the information provided.

Whether you’re importing a single shipment or managing thousands of international orders every month, one of the most important decisions you’ll make is selecting the correct Harmonized Tariff Schedule (HTS) code for your product.

An HTS code determines much more than just your customs duty. It influences whether your shipment is subject to Section 301 tariffs, Section 232 duties, anti-dumping (AD) or countervailing duties (CVD), import restrictions, partner government agency requirements, and even whether U.S. Customs and Border Protection (CBP) releases your shipment without delays.

Unfortunately, many importers rely on supplier-provided classifications or copy HTS numbers from similar products online. While this may seem convenient, it can result in overpaying duties, customs penalties, shipment examinations, or costly post-entry corrections.

This guide explains how HTS classification works, how to find the correct code for your products, and when it’s worth seeking professional assistance or requesting a binding ruling from CBP.

What Is an HTS Code?

An HTS code (Harmonized Tariff Schedule code) is the classification number used by the United States to identify imported goods and determine the customs duties, taxes, and regulatory requirements that apply at the border.

The system is based on the Harmonized Commodity Description and Coding System (HS), developed by the World Customs Organization (WCO). More than 200 countries use the first six digits of the HS system, creating a standardized language for international trade.

The United States expands this global system by adding additional digits to create the Harmonized Tariff Schedule of the United States (HTSUS).

A standard U.S. HTS number contains 10 digits:

8471.30.0100

Each group of numbers narrows the classification.

DigitsMeaning
84Chapter
8471Heading
8471.30Subheading
8471.30.0100U.S. statistical suffix

The more specific the classification becomes, the more accurately CBP can determine the applicable duty rates, trade remedies, licensing requirements, and admissibility rules.

Every commercial product entering the United States requires an HTS classification before customs clearance.

Why HTS Classification Matters

Choosing the correct HTS code is one of the most important compliance responsibilities for every importer. While the code itself appears to be just a string of numbers, it determines nearly every customs obligation associated with your shipment.

A correct classification affects:

An incorrect classification can create expensive consequences.

For example, if an importer classifies a wireless speaker as a generic electronic accessory instead of an audio reproduction device, the shipment may receive the wrong duty treatment. If CBP discovers the error during an examination or audit, the importer may owe additional duties, interest, penalties, and administrative costs.

Classification mistakes can also delay cargo while CBP reviews supporting documentation or requests additional technical information.

In some cases, businesses unknowingly overpay duties for years simply because they selected a broader tariff heading than necessary.

Getting the HTS code right from the beginning helps reduce costs while improving customs compliance.

How the HTS Code Structure Works

Although the HTS looks complex, it’s built using a logical hierarchy. Each set of digits narrows the product description until only one classification remains.

Let’s use a laptop computer as an example.

8471.30.0100

Breaking it down:

DigitsDescription
84Nuclear reactors, boilers, machinery and mechanical appliances
8471Automatic data processing machines
8471.30Portable computers weighing less than 10 kg
8471.30.0100Specific statistical reporting category

Each additional level adds more detail.

Think of the process like navigating folders on your computer:

Electronics        Computers Portable      Computers      Laptop Computers

This layered approach allows customs authorities to classify millions of different products using a standardized framework.

Step 1 – Understand Exactly What You’re Importing

Finding the correct HTS code starts long before you open the tariff schedule.

Before searching any database, you need to understand your product in detail. CBP classifies products based on their objective characteristics, not on marketing descriptions or product names.

Ask yourself:

These details often determine the applicable chapter.

Consider two products that appear almost identical:

Although both are plastic containers, their principal uses differ significantly, which may place them under completely different tariff headings.

Similarly, a cotton shirt and a polyester shirt may look identical to consumers, but they often fall under different tariff classifications because textile composition is a key classification criterion.

The more technical information you gather before beginning your search, the easier the classification process becomes.

Useful documentation includes:

Having complete documentation also makes it easier if CBP later requests additional information during an examination.

Step 2 – Start With the HTSUS Chapters

Once you understand your product, the next step is identifying the appropriate HTSUS Chapter.

The Harmonized Tariff Schedule contains 99 chapters, each covering a broad category of products.

Examples include:

ChapterProduct Category
01Live animals
02Meat
39Plastics
61Knitted apparel
62Woven apparel
73Iron and steel articles
84Machinery
85Electrical machinery
87Vehicles
90Medical and scientific instruments

Rather than searching randomly, begin with the chapter that best describes your product.

However, don’t stop after finding what appears to be the correct chapter.

Every section contains important legal notes that define what belongs, and just as importantly, what does not belong in that chapter.

Read the Section Notes

Section Notes apply to multiple chapters and provide legal definitions used throughout the tariff schedule.

They frequently explain:

Ignoring these notes is one of the most common classification mistakes made by inexperienced importers.

Review the Chapter Notes

Chapter Notes provide additional legal guidance specific to a particular chapter.

For example, Chapter Notes may clarify:

Many classification disputes are resolved simply by reading the relevant Chapter Notes before selecting a heading.

Step 3 – Apply the General Rules of Interpretation (GRIs)

The General Rules of Interpretation (GRIs) form the legal foundation of HTS classification. Every customs broker, CBP import specialist, and trade compliance professional relies on these rules when determining the proper classification for imported merchandise.

Although there are six GRIs, they are applied in sequence. If Rule 1 provides the answer, there is no need to continue to Rule 2 or beyond.

Understanding these rules helps explain why two seemingly similar products may receive entirely different HTS codes.

GRI 1 – Classification by Heading and Legal Notes

GRI 1 is the starting point for every classification. It states that goods should first be classified according to the wording of the headings, along with the relevant Section Notes and Chapter Notes.

In practice, this means you should never choose a heading based solely on a product’s appearance or marketing description. The legal text of the tariff schedule always takes priority.

GRI 2 – Incomplete, Unfinished, or Mixed Goods

GRI 2 expands classifications to include unfinished products that already possess the essential character of the finished item.

For example, an unassembled office chair shipped in multiple boxes is generally classified as a complete office chair rather than as separate parts.

GRI 2 also addresses mixtures and combinations of materials, requiring additional analysis when products are made from more than one substance.

GRI 3 – When Multiple Headings Could Apply

Sometimes a product appears to fit under more than one heading.

GRI 3 provides tie-breaking rules by considering factors such as:

This rule is especially important for composite goods, gift sets, multifunction devices, and products made from multiple materials.

Step 4 – Use Official CBP Resources to Narrow Your Classification

Once you’ve identified the most likely chapter and applied the General Rules of Interpretation (GRIs), it’s time to verify your findings using official government resources. While commercial HTS lookup tools can be helpful, the most reliable sources come directly from U.S. Customs and Border Protection (CBP) and the U.S. International Trade Commission (USITC).

Using these resources before filing your customs entry can help reduce classification errors and provide stronger support if CBP questions your declared HTS code.

Use the HTSUS Search Tool

The Harmonized Tariff Schedule of the United States (HTSUS) is the official tariff schedule used for imports.

Instead of searching by a product’s brand name, search using objective descriptions.

For example:

Start broadly, then gradually narrow your search until you find the heading that best matches your product’s material, function, and intended use.

Always read the full tariff description, not just the heading title, as many classifications contain important exclusions and qualifications.

Search Previous CBP Rulings

One of the most valuable, but often overlooked, classification resources is the Customs Rulings Online Search System (CROSS).

CROSS contains thousands of legally issued CBP classification rulings covering products imported by businesses across nearly every industry.

Searching CROSS allows you to see how CBP has previously classified products with similar specifications.

For example, if you’re importing:

there is a good chance CBP has already issued a ruling on a comparable product.

Although another company’s ruling is not legally binding on your imports, it provides excellent guidance on CBP’s reasoning and interpretation.

Review Binding Rulings

If your product is unusual, highly technical, or carries significant duty exposure, reviewing existing binding rulings can be invaluable.

Binding rulings typically include:

Reading these decisions helps you understand why CBP selected a particular classification, not just which code they assigned.

Step 5 – Confirm Country-Specific Tariffs

Finding the correct HTS code is only part of the process.

Once you’ve identified your classification, you also need to determine whether additional tariffs or trade remedies apply based on your product’s country of origin.

Many importers mistakenly assume the HTS duty rate is the final amount payable. In reality, additional tariff programs can significantly increase the landed cost of imported goods.

These include:

Section 301 Tariffs

Section 301 duties primarily apply to many products imported from China.

Depending on the product and applicable tariff list, these additional duties can substantially increase the total duty payable.

Even products with a low or zero Most Favoured Nation (MFN) duty rate may become significantly more expensive once Section 301 tariffs are applied.

Section 232 Tariffs

Section 232 measures affect certain imports of:

These tariffs are imposed for national security reasons and apply independently of the normal HTS duty rate.

Chapter 99 Provisions

Many trade remedies, including Section 301 and Section 232 measures, require importers to declare an additional Chapter 99 tariff number alongside the regular HTS classification.

Missing a required Chapter 99 number may result in customs corrections, additional duties, or delayed cargo release.

Anti-Dumping and Countervailing Duties (AD/CVD)

Some imported products are also subject to:

These measures can exceed the normal customs duty by several hundred percent in certain industries.

Products commonly affected include:

Before importing, it’s important to verify whether your HTS code is associated with any active AD/CVD orders.

Common HTS Classification Mistakes

Even experienced importers occasionally make classification mistakes. Fortunately, many of these errors are preventable with a structured approach.

Relying on Your Supplier’s HTS Code

Many overseas suppliers provide an HTS or HS code on commercial invoices. While this information may be useful as a starting point, it should never be accepted without verification.

Suppliers often classify products according to their own country’s tariff schedule, which may differ from the U.S. HTSUS.

As the Importer of Record, you remain legally responsible for the accuracy of the classification.

Choosing a Product Based on Appearance

Classification depends on legal definitions, not how a product looks.

For example, two visually similar storage containers may fall under completely different tariff headings depending on whether they are intended for household use, medical applications, or industrial packaging.

Ignoring Material Composition

Material frequently determines classification.

A leather wallet, synthetic wallet, and textile wallet may appear nearly identical, yet each can have a different HTS code.

Always confirm the exact material breakdown before selecting a tariff heading.

Ignoring Principal Use

Some chapters classify products based primarily on how they are used rather than what they are made from.

Understanding the product’s principal function is often just as important as understanding its composition.

Copying a Competitor’s HTS Code

Finding another importer’s classification online does not guarantee it is correct, or appropriate for your specific product.

Small design differences, manufacturing methods, materials, or technical features can completely change the correct classification.

Schedule B vs HTS Code

One of the most common questions from first-time importers concerns the difference between an HTS code and a Schedule B number.

Although they look similar, they serve different purposes.

FeatureHTS CodeSchedule B
Used ForImportsExports
Maintained ByUSITCU.S. Census Bureau
Determines DutyYesNo
Used by CBPYesLimited
Length10 digits10 digits

Both systems share the same first six digits because they are based on the international Harmonized System.

However, importers should avoid using a Schedule B number as a substitute for an HTS classification.

When Should You Request a Binding Ruling?

Sometimes the correct classification isn’t obvious.

If your product is:

consider requesting a Binding Ruling from CBP.

A binding ruling is an official written decision issued by CBP that specifies the proper HTS classification for your product.

Benefits include:

Although obtaining a ruling requires preparation and supporting documentation, it is often worthwhile for businesses importing the same product repeatedly.

HTS Classification Checklist

Before submitting your customs entry, ask yourself:

✔ Have I identified the product’s exact material composition?

✔ Do I understand its principal use?

✔ Have I confirmed the country of origin?

✔ Did I read the relevant Section Notes?

✔ Did I review the Chapter Notes?

✔ Have I searched previous CBP CROSS rulings?

✔ Does Section 301 apply?

✔ Does Section 232 apply?

✔ Is a Chapter 99 tariff number required?

✔ Could Anti-Dumping or Countervailing Duties apply?

Completing this checklist before filing an entry can help prevent costly classification errors and customs delays.

Frequently Asked Questions

What is an HTS code?

An HTS code is the ten-digit tariff classification used by the United States to identify imported products and determine applicable customs duties, tariffs, and import requirements.

How many digits are in an HTS code?

A U.S. HTS code contains ten digits. The first six digits are internationally standardized under the Harmonized System, while the final four digits are specific to the United States.

Is an HS code the same as an HTS code?

Not exactly. The HS code refers to the internationally standardized six-digit classification, while the HTS code expands it into a ten-digit U.S.-specific tariff number.

Can two similar products have different HTS codes?

Yes. Differences in material composition, principal use, manufacturing method, or technical specifications can result in different tariff classifications.

What happens if I use the wrong HTS code?

Using an incorrect HTS code may lead to customs delays, duty reassessments, interest charges, penalties, cargo examinations, or post-entry audits by CBP.

Can CBP change my classification?

Yes. CBP may review your declared classification during cargo examinations, post-entry reviews, or audits and reclassify the product if it determines another HTS code is more appropriate.

How do I request a binding ruling?

You can submit a binding ruling request directly to CBP with detailed product descriptions, technical documentation, specifications, and supporting materials. CBP will review the submission and issue a written classification decision.

Can Clearit help classify my products?

Yes. Clearit can assist importers with HTS classification, customs compliance, tariff reviews, and customs clearance to help reduce delays and ensure accurate entries.

Disclaimer

This guide is intended for general informational purposes only and should not be considered legal or customs advice. Product classification depends on the specific characteristics of each item, applicable legal notes, and current CBP guidance. Before importing commercial shipments, verify your HTS classification using official CBP resources or consult a licensed U.S. customs broker.

Filing for IEEPA refunds through CAPE involves more than just submitting entry numbers—it requires accurate data, proper formatting, and a clear understanding of CBP requirements and timelines. Working with a broker who already has access to your entry history and operates directly within ACE can simplify the process and reduce the risk of delays or errors. Below are some of the key reasons importers choose Clearit to manage their refund filings.

Why use Clearit to handle my refunds?

  1. We already have the entry data

For entries filed by Clearit, we already have the entry numbers, entry dates, Chapter 99 tariff lines, liquidation status, duty amounts, and supporting entry records.

This allows us to review your entry history more efficiently, identify which entries may be eligible, and reduce the risk of missing refund opportunities.

  1. We know which entries qualify right now

Phase 1 is not a blanket refund process for all entries.

It generally applies to unliquidated entries and certain entries liquidated within the allowed window. Entries involving protests, reconciliation, drawback, AD/CVD issues, or other complexities may be excluded from Phase 1.

Clearit can help determine which entries appear to qualify under the current process.

  1. Lower risk of technical rejection

The CAPE declaration has specific formatting requirements.

For example:

  • The file must be submitted as a CSV
  • The header must be exact
  • Entry numbers must be formatted properly
  • Duplicate entries must be avoided
  • Each declaration may include up to 9,999 entries

Small formatting errors can cause automated rejections. Clearit can help reduce that risk by preparing and submitting the file correctly.

  1. Clearit can reconcile refund eligibility against the actual entry history

Clearit can review each applicable entry to confirm whether:

  • IEEPA duty was actually paid
  • The entry has liquidated
  • Other tariff programs were involved
  • CBP may net the refund against other underpayments or debts

This helps ensure the refund request is based on the actual entry record.

  1. Faster correction if CBP rejects entries

ACE provides validation history and error reports when entries are rejected or require correction.

Because Clearit works in ACE daily, we can review the rejection reasons, correct missing or incorrect entry data, and resubmit omitted or rejected entries more efficiently.

  1. Better deadline management

For entries that do not qualify for Phase 1, protest deadlines may still matter.

Importers should monitor protest deadlines, which are typically 180 days from liquidation, in order to preserve refund rights.

  1. Cleaner audit trail

Because Clearit filed the original entry, we can tie the refund request back to the original entry package.

This may include invoices, HTS codes, Chapter 99 applications, duty calculations, liquidation history, and other supporting entry documents.

If you don’t currently have an ACE account, you’ll need to create one before moving forward with CAPE refund filings. The application process is straightforward and typically takes just a few minutes to complete, though CBP approval may take up to 1–2 weeks. Follow the steps below to set up your ACE account and prepare for refund submission.

If you do not currently have an ACE account, please complete the following steps.

The application itself typically takes about 5 minutes to complete. Please note that CBP’s review and approval process may take 1–2 weeks.

  1. Download the ACE application

Download the ACE Secure Data Portal account application here:

https://www.cbp.gov/document/guidance/ace-secure-data-portal-account-application

  1. Complete Section A

Complete Section A with your company’s information.

Then complete Section A.1.

  1. Select IMPORTER as your primary account type

Make IMPORTER your primary account type by clicking and selecting P.

  1. Enter your full importer number

Enter your full importer number, including the CBP-assigned suffix.

Example: EIN + suffix, such as 12-3456789

  1. Complete Section B

Skip to Section B.

Complete Part 2: Legal Entity.

  1. Complete Sections C and D

Complete Sections C and D.

Then submit the application by email using the button at the bottom of the form.

  1. Include the correct subject line

When submitting your application, include your company name and EIN in the email subject line.

  1. Wait for CBP approval

CBP’s review and approval process for your ACE account may take 1–2 weeks.

Once your ACE account is approved, you can move to the next step, which is granting Clearit cross-account access.

SUBMIT button troubleshooting

If the SUBMIT button does not respond, please complete the following steps.

  1. Save the completed application as a PDF

Save the completed ACE application as a PDF.

  1. Email the completed application

Send an email to [email protected] and attach the completed application PDF.

  1. Use the correct subject line

In the subject line, include your company name and IOR number, including the “00” suffix.

  1. Watch for the automated confirmation

You should receive an automated email confirming receipt.

The response typically states that CBP will respond within 3–5 business days.

To allow Clearit to file CAPE refund claims on your behalf—especially for shipments not originally cleared by Clearit—you’ll need to grant access to your ACE account. This process ensures we have the appropriate permissions to submit filings efficiently and without delays. Follow the steps below to add Clearit as a user in your ACE account.

Understanding the cost structure for CAPE refund filings is an important part of planning your duty recovery strategy. Clearit has designed its pricing to be straightforward and accessible, allowing importers to pursue refunds without the complexity or high fees often associated with customs-related services. Below is a breakdown of how our pricing works for IEEPA refund filings.

Clearit is offering IEEPA CAPE refund filing at one of the lowest prices in the industry, with simple, transparent pricing based on a flat filing fee plus a small percentage of the total refund recovered. Our goal is to make the refund process accessible and cost-effective, so eligible importers can recover duties without unnecessary complexity or inflated service fees. 

For duty recovery under $5,000:

  • $200.00 for the first entry
  • $125.00 per additional entry

For duty recovery over $5,000:

  • $200.00 per entry + 4% of the total duties recovered per filing

[Join the IEEPA Refund List]

As the CAPE refund process rolls out, one of the most common questions importers have is whether their shipments qualify for an IEEPA refund. Eligibility depends on several factors, including the role of the Importer of Record, the type of duties assessed, and the current status of the entry within CBP’s processing timelines. Below is a breakdown of who may qualify and which entries are currently eligible under Phase 1 of CAPE.

 

Who is eligible for an IEEPA refund?

The Importer of Record (IOR) for U.S. entries, including both commercial and individual importers, may be eligible for an IEEPA refund if IEEPA-based duties were assessed and paid on those entries.

These duties are typically associated with IEEPA-related Chapter 99 HTSUS tariff lines, including reciprocal/fentanyl tariff programs that were later ruled unlawful.

CBP is handling the refund process through CAPE in ACE. Phase 1 is currently limited to certain unliquidated entries and certain entries within 80 days of liquidation.

Which entries are eligible for an IEEPA refund under Phase 1 of CAPE?

Phase 1 generally applies to entries impacted by IEEPA tariffs that were later modified, excluded, or ruled unlawful.

Eligible entries generally include entries that are:

  • Unliquidated, or
  • Within the protest period, typically within 180 days after liquidation

CBP has limited Phase 1 to specific tariff programs and timeframes identified in its CSMS guidance.

Note: Most entries liquidate approximately 10–11 months after the date of entry, unless CBP extends, suspends, or accelerates liquidation. Once an entry liquidates, the importer generally has 180 days to file a protest if they need to challenge or preserve rights related to that entry. 

U.S. Customs and Border Protection (CBP) has announced an important upcoming development that may create refund opportunities for importers and businesses.

Beginning April 20, 2026, CBP will launch Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) system, which introduces a new electronic process for submitting certain duty refund claims directly through the ACE Portal.

This new system is designed to streamline the submission and processing of eligible refund claims, particularly those related to IEEPA duties, by allowing importers and brokers to upload entry data and receive consolidated refunds electronically.

What this means for importers

How we can help

Our team is fully prepared to assist with:

Importers are encouraged to assess whether their shipments may qualify and to understand how this new process could apply to their operations.

Ask us about service options and competitive rates for CAPE refund processing.

If you have any questions or would like to begin a review, please fill out this form.

Ready to simplify your importing process? Our Quick-Start Guide breaks down the essentials you need for smooth customs clearance, from bonds to documentation, so you can get your shipments moving faster and with less stress.

Check out our Quick-Start Guide to Stress-Free Importing for tips on bonds, documentation, and smooth customs clearance.

At Clearit, we love spotlighting the amazing businesses we support through customs and beyond. In our Cleared for Success series, we sit down with clients who are making waves in their industries to learn more about their journey, the challenges they’ve overcome, and how Clearit has helped streamline their importing process.

This week, we’re thrilled to feature Better Boat, a brand making life easier for boat lovers across North America.

Tell us about your business! What do you sell, and who’s your target audience?


We operate Better Boat, a leading brand of marine accessories tailored to recreational boat owners across North America. Our products are designed for everyday boaters from pontoon and bass boat owners to weekend cruisers looking for easy-to-use, high-quality cleaning and maintenance solutions.

What challenges were you facing with importing before Clearit?


Before Clearit, navigating customs compliance and documentation into Canada was slow, expensive, and unpredictable. We couldn’t figure it out ourselves and didn’t want to deal with traditional brokers, creating unnecessary delays and extra fees.

How has Clearit helped you solve those challenges?


Clearit made the entire cross-border process simple and reliable. Their platform gives us fast access to filings and updates, and their team understands the nuances of the business. We’ve been able to ship faster, avoid surprise costs, and maintain compliance without slowing down operations.

What part of the Clearit experience has been most valuable for your business?


Speed and clarity. Their digital-first system and responsive support team keep things moving without friction. The ability to track and resolve issues quickly has reduced stress on our logistics team and allowed us to scale Canadian sales more confidently.

Any results or wins you can share?

We have been able to increase our Canada sales volumes by 300% over the last year, largely attributable to just being in stock and expanding our catalog given the simplicity.

What would you say to another brand thinking about using Clearit?

If you’re an ecommerce brand selling into Canada, Clearit is a no-brainer. They bring speed, transparency, and expertise that typical brokers just can’t match. They have been great for us.

Where can people find you online?

Website: www.betterboat.com
Amazon Store: amazon.com/betterboat
Instagram: @betterboat

From simplifying compliance to scaling cross-border sales, Better Boat is a perfect example of how smart logistics can fuel growth. Stay tuned for more client stories in our Cleared for Success series—and if you’re looking to streamline your own importing process, we’re here to help.