USA — AMS, ISF & FMC filings

2026-06-09 By Jan van den Herik

Ocean cargo to the United States triggers three separate advance filings: AMS (per bill of lading), ISF 10+2 (at house-bill level), and FMC compliance for the NVOCC. AMS and ISF are both due 24 hours before loading at the foreign port. Miss one and you risk a 'do not load' and a $5,000 penalty.


Sending ocean cargo to the United States is not one filing but three, each with a different owner, a different bill-of-lading level, and a hard deadline tied to loading at the foreign port, not departure. Miss one and the consequence isn't a fine later: you can get a "do not load" before the box ever sails, plus $5,000 penalties. What keeps it on track is a forwarder who files all three on time. Nexport Logistics handles the AMS, ISF and FMC side for you in the Nexportal platform.

1. AMS: the advance manifest (per bill of lading)

AMS (Automated Manifest System, filed through CBP's ACE Ocean eManifest) is the 24-hour rule: the cargo manifest must reach US Customs (CBP) 24 hours before the container is laden at the foreign port. The key point: it's per bill of lading, and the responsibility is split.

  • The ocean carrier files the Master B/L (MBL) via vessel AMS.
  • The NVOCC files its own House B/L (HBL) separately, under its own SCAC code, electronically linked to the master.

The carrier cannot file the NVOCC's house bill, and the NVOCC can't rely on the carrier to do it. So on a consolidated shipment there is an AMS filing for the MBL and one for each HBL. CBP returns statuses like "Bill on File" and "ISF Match".

2. ISF: Importer Security Filing "10+2" (at house-bill level)

ISF is the security filing: 10 data elements from the importer plus 2 from the carrier, due no later than 24 hours before the cargo is laden aboard the vessel.

  • The importer's 10: seller, buyer, importer-of-record number, consignee number, manufacturer/supplier, ship-to party, country of origin, HTSUS number, container stuffing location, consolidator.
  • The carrier's 2: vessel stow plan and container status messages.

ISF is filed at the lowest bill-of-lading level in AMS, the House B/L (HBL), or, if there is no house bill, the direct / simple B/L. The B/L number is the link between the ISF and the manifest, which is why the AMS and ISF have to match.

Penalty: $5,000 in liquidated damages per ISF violation (late, inaccurate, or not filed); severe or repeat failures can trigger a "do not load" at origin.

3. FMC: the NVOCC/forwarder's licence to carry

The third one isn't per shipment. It's about who is allowed to move your cargo. The Federal Maritime Commission (FMC) regulates ocean carriers and NVOCCs in US trades. Before offering services, an NVOCC must:

  • hold an FMC OTI licence (Ocean Transportation Intermediary),
  • post proof of financial responsibility (an FMC bond), and
  • publish a tariff.

Rates are agreed either via an NRA (Negotiated Rate Arrangement, kept in the NVOCC's records) or an NSA (NVOCC Service Arrangement). Since the FMC's 2018 rule change, NSAs no longer have to be filed with the FMC; they take effect on signing. (VOCC service contracts are still filed via SERVCON, by the carrier.) The lion's share of containerised cargo moves under service contracts or NSAs. Using a forwarder that isn't FMC-compliant is itself a risk to your shipment.

The timing, in one view

Filing Who files B/L level Deadline
AMS Carrier (MBL) + NVOCC (HBL) Every B/L 24 h before loading
ISF 10+2 Importer/agent (10) + carrier (2) House / direct B/L 24 h before loading
FMC NVOCC/forwarder n/a (licence + contract) In place before you book

Both AMS and ISF run off loading at origin, not sailing. In practice that means they're due before the vessel leaves, often weeks before it reaches the US.

Two rules that trip people up

Manifest by the lowest external packaging unit. CBP wants the quantity on the AMS and ISF stated as the lowest external packaging unit, and pallets and containers are explicitly not acceptable. So 500 cartons stacked on 3 pallets are manifested as 500 cartons, not 3 pallets and not the individual cans inside. A container with 10 pallets of 200 cartons is 200 cartons. The AMS and ISF must carry the same figure; a mismatch is one of the most common reasons a box gets held. The "lowest external" unit is the smallest unit still presented to the outside: loose cans inside a sealed carton are not the manifest unit, the carton is.

Weight: stay road-legal in the US. A container can be loaded heavier than a US truck may legally carry. The federal gross-vehicle-weight limit on interstates is 80,000 lbs (about 36.3 t) for tractor, chassis, container and cargo combined. That leaves a practical cargo payload of roughly 37,500 lbs (~17 t) in a 20' and 43,500 lbs (~19.7 t) in a 40' to stay legal without an overweight permit. Load above that and the box either needs a state overweight permit (often capped around 90,000 lbs GVW, with route and timing limits) or it cannot be trucked from the port at all. Plan the gross weight against the road limit, not just the container's structural maximum.

How Nexport Logistics handles it

We file the AMS for every bill of lading (master and house), submit the ISF 10+2 at the right B/L level and on time, and operate as an FMC-compliant party with the tariff and service-contract side in order, so your US shipment doesn't hit a "do not load" or a penalty over a missed deadline. It runs with your B/L, Customs and booking in Nexportal.

Shipping ocean freight to the USA? Email info@nexportlogistics.nl.

Official sources: CBP — Importer Security Filing "10+2" · CBP — ACE import manifest · FMC — how to file service contracts. Related: Customs · Sea Freight · Bill Of Lading