Who files what on the US side, and what they need from the exporter
Four separate parties file something with the US government for one container from India, and unless you sell DDP, none of them is you. The Importer Security Filing (ISF) is filed by the ISF Importer, which for ordinary cargo is the goods' owner, purchaser, consignee or an agent such as a licensed customs broker.[1] The ocean carrier, or an NVOCC licensed by or registered with the Federal Maritime Commission, files the cargo declaration under the 24-hour rule.[3] The customs entry is filed by the importer of record on its own account or by a licensed customs broker acting for it, and the product agencies (FDA, APHIS, CPSC) get their data through that entry or their own systems.[5][14]
What ties them together is that the data comes from your side: who made the goods, who sold them, where the container was stuffed, what is in it, how it is classified and how it is marked. A wrong or vague answer at origin becomes a late or inaccurate ISF, a manifest that fails CBP's description rules, or an exam at the US port. The paperwork you prepare in India is in the export documents checklist; the whole process from IEC to delivery is in the India to USA export guide.
| Requirement | Who files in the US | What the exporter supplies | Deadline |
|---|---|---|---|
| Importer Security Filing (ISF 10+2) | The ISF Importer (owner, purchaser or consignee) or its agent; the agent need not be a customs broker and can be a foreign freight forwarder[1][2] | Manufacturer or supplier name and address, seller, buyer, ship-to party, container stuffing location, consolidator, country of origin, HTS to 6 digits[1] | 24 hours before lading at the Indian port; stuffing location and consolidator no later than 24 hours before US arrival[1] |
| Advance cargo declaration (24-hour rule, AMS) | The vessel carrier; an FMC-licensed NVOCC may file its own house bill data[3] | Precise cargo description or 6-digit HTS, piece count at the lowest packaging unit, your name and Indian address as shipper, consignee, container and seal numbers[3] | 24 hours before lading at the Indian port[3] |
| Customs entry and entry summary | The importer of record on its own account, or a licensed customs broker acting for it[5] | Commercial invoice meeting 19 CFR 141.86, packing list detail per package, goods marked with the country of origin[4][6] | At entry; marking must be on the goods at the time of importation[6] |
| FDA food facility registration and prior notice | Registration by the Indian facility itself; prior notice by a party with knowledge of the required information, usually the importer or broker[8][9] | FDA registration number of the manufacturing facility, a US agent, FDA country of production, shipper identity[8][9] | Register before shipping; prior notice no less than 8 hours before the vessel arrives[9] |
| FDA drug and device establishment registration | The Indian establishment registers and lists, with a US agent[10][11] | Registration and listing numbers; US agent details[11] | Before the goods are offered for import[11] |
| Wood packaging (ISPM 15) | No filing; an inspector at the port of first arrival checks the mark[12] | Pallets, crates and dunnage treated and stamped with the IPPC mark, IN country code, producer number and HT or MB[12] | No deadline to file; the mark must be on the packaging when it arrives, or the inspector may order immediate re-export[12] |
| Lacey Act plant declaration | The importer of record or its agent, in ACE[13] | Scientific name (genus and species) of each plant material and the country where it was harvested[13] | With the entry[13] |
| CPSC certificate of compliance (GCC or CPC) | The importer, as the finished product certifier, files the certificate data in ACE[14] | Date and place of manufacture, test reports and lab details the certificate must cite[14] | At the time of filing the entry[14] |
ISF 10+2: the data your buyer's filer needs from you
The ISF is a CBP security filing for cargo arriving by vessel. The ISF Importer, or an authorized agent, must transmit ten data elements electronically, in English, with a CBP bond behind the filing.[1] Your buyer is usually the ISF Importer, but the filing agent does not have to be a licensed customs broker; CBP's FAQ says a foreign freight forwarder can be a filing agent.[2] Airlift USA files the ISF as the NVOCC when the shipment moves on its house bill of lading; see our Importer Security Filing service. Eight of the ten elements come from your side of the transaction.[1]
- Manufacturer (or supplier): name and address of the entity that last manufactured, assembled, produced or grew the goods, or of the party supplying the finished goods in India.[1]
- Seller: the last known entity by whom the goods are sold. For a merchant exporter this is you, not the factory.[1]
- Buyer: the last known entity to whom the goods are sold.[1]
- Ship-to party: the first party that will physically receive the goods after customs release, often a warehouse rather than the buyer's head office.[1]
- Container stuffing location: the physical place where the goods were stuffed, so the factory for a factory-stuffed box or the CFS for a CFS-stuffed one.[1]
- Consolidator (stuffer): the party who stuffed the container or arranged the stuffing.[1]
- Country of origin: the country of manufacture, production or growth under US rules, not the country of export.[1]
- Commodity HTSUS number: at least six digits of the US Harmonized Tariff Schedule; both it and your ITC-HS code follow the Harmonized System, so the first six digits should agree.[1]
ISF timing, updates and what a late or wrong ISF costs
Seller, buyer, importer of record number, consignee number, manufacturer, ship-to, country of origin and HTS must be filed no later than 24 hours before the cargo is laden aboard the vessel at the foreign port. The stuffing location and consolidator may follow, as early as possible and no later than 24 hours before arrival at a US port.[1] In practice your filer needs the data at or before the carrier's documentation cut-off at Nhava Sheva, Mundra or Chennai, not when the bill of lading is issued. The shipping bill guide covers the Indian cut-offs that run in parallel.
Four elements are flexible: manufacturer, ship-to party, country of origin and HTS may be filed on the best available data and must be updated as soon as better information exists, in no event less than 24 hours before arrival.[1] The filer must update the ISF if anything changes before the goods reach a US port, and withdraw it, giving CBP the reason, if the goods will no longer be imported.[1] The manufacturer, country of origin and HTS must be linked to one another line by line,[1] and the ISF must match the bill of lading at least 24 hours before arrival at the first US port, so send your filer the house bill number as soon as it is known.[2]
The ISF is enforced through liquidated damages on the filer's bond: $5,000 per late ISF, $5,000 per inaccurate ISF and $5,000 for the first inaccurate update. CBP's examples of inaccuracy include no bill of lading match, a flexible filing never updated, and discrepancies found at the 6-digit HTS level at inspection.[2] CBP also says it may examine cargo more intensively when it does not receive ISF data in time to target the shipment before arrival.[2] The claim lands on your buyer or its agent and can come back to you as a chargeback or a lost customer, so treat the ISF data sheet as one of your export documents.
AMS and the 24-hour rule: the bill of lading data the carrier files
Separately from the ISF, CBP must receive the vessel's cargo declaration (the electronic equivalent of CBP Form 1302) from the carrier through the Automated Manifest System 24 hours before the cargo is laden at the foreign port. An NVOCC licensed by or registered with the Federal Maritime Commission and holding an International Carrier Bond may transmit its own house bill data directly; otherwise it must disclose the full cargo information to the vessel carrier, which files it.[3] A carrier that fails to file, or an NVOCC that elects to file and does so late or inaccurately, faces liquidated damages of $5,000 per violation under the international carrier bond, on top of any civil penalty.[3]
The manifest is built from your shipping instructions, and CBP's content rules are specific. The description must be precise, or the 6-digit HTS number if the shipper provides it; "FAK", "general cargo" and "STC" (said to contain) are not acceptable. The quantity must be the lowest external packaging unit: a container of 10 pallets holding 200 cartons is manifested as 200 cartons.[3] The shipper on each house bill must be the foreign vendor, supplier or manufacturer with a foreign address, not the forwarder, NVOCC or consolidator. The consignee is the party to whom the cargo will be delivered in the United States, or the named "to order" party, with any other commercial party as notify party. Container numbers and all seal numbers are required.[3]
For you this means the description on your shipping instructions, your commercial invoice and your packing list should be the same words, and the bill of lading carton count should equal the packing list. "Granite slabs, polished, 20 crates" clears; "stone products, 1x20' STC" does not.
The customs entry: documents the licensed broker needs from you
The entry is filed by the importer of record on its own account or by a licensed customs broker acting for it,[5] and its backbone is your commercial invoice. 19 CFR 141.86 requires each invoice to set forth: the US port of entry; the time, place and parties of the sale; a detailed description of each item including the name by which it is known, grade or quality, and the marks and numbers of the packages; quantities in Indian or US weights and measures; the purchase price of each item in the currency of the purchase; all charges itemized by name and amount, including freight, insurance, commission, packing and containers (packing and inland freight to the port need not be itemized if included in the price and identified as such); all rebates, drawbacks and bounties allowed on exportation; the country of origin; and any goods or services furnished free for production of the goods (assists such as dies, molds, tools or engineering) not included in the price.[4]
The invoice and attachments must be in English or carry an accurate English translation, each invoice must state in adequate detail what merchandise is in each package, every discount from list price must be shown, and the invoice must name a responsible employee of the exporter who knows the transaction or can readily find out.[4] If the invoice does not disclose the weight or measure needed to assess duty, the consignee pays the cost of weighing or measuring before release.[4] Your Incoterm shapes the price column: an FOB invoice and a CIF invoice carry different charges, and the broker must separate them to reach the customs value. The Incoterms guide for Indian exporters explains which charges to show.
Country of origin marking is a condition of the goods, not a document. Every article of foreign origin, or its container, must be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article permits, so that the ultimate purchaser in the United States can read the English name of the country of origin at the time of importation.[6] Where "USA", a US city or the name of another country or locality appears on the article or its packaging in a way that could mislead, the country of origin preceded by "Made in", "Product of" or words of similar meaning must appear legibly and permanently, in close proximity and in at least comparable size.[6] Articles found not legally marked draw a notice on CBP Form 4647 to mark, re-export or destroy under CBP supervision at the importer's expense, delivery is withheld until the goods are marked or the marking duty deposited, and goods not marked, exported or destroyed before liquidation pay an additional duty of 10 percent of the final appraised value.[6] Mark the goods in India.
Textiles and apparel carry a second label under the FTC's Textile Rules: the generic fiber names and percentages by weight in order of predominance, the name or FTC registered identification number (RN) of the manufacturer or a firm marketing the product, and the country where the product was processed or manufactured.[7] Our textiles and apparel commodity page covers the lane.
Product rules by cargo type: FDA, APHIS, Lacey Act and CPSC
Customs release is not the only gate. Several US agencies regulate specific goods through registrations the Indian manufacturer must hold, declarations the importer must file, or marks that must be on the packaging. The ones that most often touch Indian exports are below; confirm your product's position with your buyer's broker and the agency itself.
Food, including spices, rice, tea, seafood and processed food. The owner, operator or agent in charge of a foreign facility that manufactures, processes, packs or holds food for consumption in the United States must register it with FDA, unless the food is further manufactured or processed (beyond labeling) at another facility outside the United States.[8] The facility must name a US agent who resides or maintains a place of business in the United States, not a mailbox or answering service; FDA will not issue a registration number until that person confirms the appointment. There is no fee. Registrations are renewed between October 1 and December 31 of each even-numbered year, so the current window closes December 31, 2026, and an unrenewed registration is treated as expired.[8] Every food shipment also needs FDA prior notice, submitted and confirmed no less than 8 hours before arrival by water or 4 hours by air, and no more than 30 calendar days ahead through ABI/ACE or 15 days through FDA's own system.[9] It must give the manufacturer's registration number (or full address and the reason the number is missing), the FDA country of production, the shipper, the importer and the ultimate consignee.[9] Food with no, inaccurate or untimely prior notice is subject to refusal and must be held within the port or exported under CBP supervision; food from an unregistered facility is placed under hold; neither FDA nor CBP is liable for the costs.[9]
Drugs and medical devices. A foreign establishment that manufactures, repacks, relabels or salvages a drug imported or offered for import into the United States must register it with FDA and designate a single US agent who resides or maintains a place of business in the United States, not a mailbox or answering service.[10] A foreign establishment that manufactures or processes a medical device for the US market must register and list its devices through FDA's electronic system and submit its US agent's details; no device may be imported unless it is listed and comes from a registered foreign establishment.[11] Our pharmaceutical and healthcare commodity page covers the lane.
Wood packaging, every commodity. Solid-wood pallets, crates, cases and dunnage must have been treated and must carry the IPPC-approved ISPM 15 mark in a visible location, preferably on two opposite sides: the IPPC symbol, the ISO two-letter country code (IN), the producer number assigned by India's national plant protection organization, and the treatment code HT (heat treatment) or MB (methyl bromide).[12] An inspector at the port of first arrival may order the immediate re-export of wood packaging that arrives without the mark.[12] For stone shippers this is the rule most often broken: the slabs comply, the untreated crate does not. See the granite and stone export guide.
Wood and plant products: Lacey Act declaration. Furniture, wooden handicrafts, essential oils, tools and many other plant-based products need a Lacey Act declaration filed by the importer of record or its agent, with ACE as the primary filing method; APHIS stopped accepting paper PPQ Form 505 on January 1, 2026.[13] Phase VII of the declaration schedule, implemented from December 1, 2024, pulled in furniture, additional essential oils, sporting goods, housewares and tools.[13] APHIS tells importers to get the scientific name (genus and species) of each plant material and where it was harvested from their suppliers, so expect your buyer to ask for species and harvest country for every wooden component.[13]
Consumer goods: CPSC certificates. For a finished consumer product made outside the United States that a CPSC rule requires to be certified, the importer is the certifier and must issue a General Certificate of Conformity or, for children's products, a Children's Product Certificate.[14] The certificate must identify the product, each rule it is certified to, the date and place of manufacture with the manufacturer's name and address, and the date, place and laboratory of testing, and the importer must eFile these data elements in ACE when the entry is filed.[14] The certifier may rely on another party's testing but stays legally responsible, and must produce the certificate to CPSC or CBP within 24 hours of a request.[14] Your buyer will ask you for the test reports and manufacturing details before the goods ship.
US duty on Indian goods as of October 15, 2026
Duty is your buyer's bill unless you sell DDP, but it shapes every price negotiation. As of October 15, 2026, goods of Indian origin pay the normal duty for their HTS line plus a 10 percent Section 301 duty imposed by the US Trade Representative on products of India, applicable to goods entered for consumption on or after 12:01 a.m. Eastern time on July 24, 2026, with exemptions for the goods listed in the notice's annexes; goods already on the water before that time and entered before July 28, 2026 were spared.[15] Section 232 goods, antidumping and countervailing orders and the quartz safeguard are separate layers; the layer-by-layer table, the dates and the exemptions are kept current in our US tariffs on India guide; the tariff simulator gives the duty, fees and Chapter 99 lines for a 10-digit HTS code and entry date, and the HTS code finder helps you reach the 10 digits from your ITC-HS code. Quote the US duty to a buyer only after the buyer's licensed customs broker has confirmed the classification.
What happens at a CBP exam, and how exporters avoid them
CBP examines whatever packages or quantities of a shipment the port director considers necessary to determine duties and check compliance with the customs laws and the other laws CBP enforces.[16] Merchandise is examined at the place of arrival unless the port director requires or authorizes another place, such as a centralized examination station (CES), and the importer bears the expense of preparing the merchandise for examination and closing the packages.[16] An exam means delay at the terminal, often a trucking move to the CES, devanning and restuffing, and possibly demurrage, all billed to your buyer. CBP says it may examine cargo more intensively when ISF data does not arrive in time to target the shipment, and that discrepancies at the 6-digit HTS level found at inspection count as an inaccurate ISF.[2] A marking exam that finds unmarked goods triggers the CBP Form 4647 notice described above.[6]
You cannot stop CBP choosing a container, but most avoidable exams come from documents that disagree with each other or with the box. These habits keep your shipments boring in the right way:
- Use one description everywhere: shipping instructions, bill of lading, commercial invoice, packing list and ISF, with ISF, manifest and entry agreeing at the 6-digit HTS heading level.[2]
- Make the carton count on the bill of lading equal the packing list, manifested at the lowest external packaging unit, never as "1 container", and record the container seal numbers on both.[3]
- Name the real manufacturer and the real stuffing location on the ISF, and send the filer the house bill number as soon as it is cut so the ISF matches the bill of lading 24 hours before arrival.[2]
- Mark the goods and their retail packaging with the country of origin in India, in English, before stuffing, and use ISPM 15 marked pallets and crates only.[6][12]
- Pick the Incoterm with the US obligations in mind: under DDP you typically act as the importer of record, which makes you the party causing the goods to arrive and therefore the ISF Importer, so the ISF, the entry and the duty become your responsibility, not the buyer's.[1]