ATA Carnet and the ISF Filing aka 10+2

An Expert's View about Law and Compliance in the United States

Last updated: 20 Jan 2011

ATA Carnet Interpretation of 10+2:

CBP has modified its computer system to accept nine types of coded transactions, of which Carnet is 06. Below is more detail on how to complete an ISF for Carnet goods.


  • Requirements 1–4 “Importer of record, consignee, buyer or owner, and seller or owner.” The holder name as listed in Box A of the Carnet will meet CBP requirements.
  • Requirement 5 “Ship to parties or to whom the goods are going.” This can be a trade show, a customer, a warehouse or the holder.
  • Requirement 6 “Manufacturer and last foreign address” for carnet purposes means the owner of the goods which is the holder. Also provide an address where the goods were last located, for example a trade show, job site or client offices.
  • Requirement 7 “Country of origin” for carnet purposes this means the places where the carnet and the goods have visited. The customs stamps on the Carnet counterfoils should be sufficient to determine which countries were visited.
  • Requirement “HTS code.” A licensed broker must classify the goods to the 6 digit level.
  • Requirement 9 “Consolidator.” The entity/person who packed the container prior to departure. This name should be known to the broker or freight forwarder.
  • Requirement 10 “Location where the consolidator packed the container.” Once again this is information that should be readily available to the broker or freight forwarder.


The additional 2 data requirements will be provided by the vessel operator and are not specific to each individual shipment.

U.S. CBP will impose penalties for breaches of 10+2 filing starting January 26th, 2010. For further information on mitigation guidelines on the liquidated damages and penalties please go to page 29 of the following PDF document published by U.S. CBP.

******Update on ISF enforcement: The one year period of delayed penalty enforcement ISF ended on January 26th, 2010. However U.S. Customs and Border Protection have unveiled a strategy for graduated enforcement of the ISF. Each three month quarter of this year, U.S. CBP will mark a new phase of ISF enforcement. For complete details on each of these quarters please Click Here courtesy of Bruce H. Leeds Esq., Braumiller Schulz LLP.

The above constitutes USCIB’s understanding of the ISF requirements as they apply to ATA Carnets. For further details please check with your broker or contact U.S. CBP. For the complete U.S. CBP Importer Security Filing “10+2” Program FAQs please click here.

Useful links:

  • ATA Carnet : Learn about temporary exports and imports, the ATA (and Tecro) Carnet and related export services.
Posted: 19 January 2011, last updated 20 January 2011

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