Importer Security Filing for a Contract Furniture Container Shipped to the United States: What 19 CFR Part 149 Asks For and When
Who files, which ten data elements are asked for and when each part is due, read from the text of 19 CFR Part 149
A container of contract furniture that crosses the Pacific to a United States port by vessel does not only carry goods. It also carries a set of data that has to reach United States Customs and Border Protection before the container is loaded in China. That filing is the Importer Security Filing, and its rules are in Part 149 of Title 19 of the Code of Federal Regulations.
This article reads Part 149 for an FF&E contractor or project buyer who needs to know who files, which data is asked for and when each part is due. FBM Furniture works with companies only: Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers. It sets out what the regulation text says. It does not cover penalties, duty rates or CBP guidance, and it is not legal advice; your customs broker or counsel confirms how the text applies to your shipment.
Who the text treats as the filer
Section 149.1(a) defines the Importer Security Filing Importer, or ISF Importer, as 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, the text says the ISF Importer is the goods’ owner, purchaser, consignee, or an agent such as a licensed customs broker.
Section 149.2(a) then says that, for cargo arriving by vessel, the ISF Importer or an authorised agent must submit the filing elements in English through a CBP-approved electronic interchange system. The text allows an agent to file for the ISF Importer, so the practical question for a project team is which named party will act as the ISF Importer and who has the authority to transmit on its behalf.
Which shipments the filing applies to
Section 149.2(a) applies to cargo arriving by vessel and excepts bulk cargo under §149.4(a). Section 149.1(c) defines bulk cargo as homogeneous cargo stowed loose in the hold and not enclosed in any container, such as oil, grain, coal or ore, or articles that require mechanical handling such as bricks, pig iron, lumber or steel beams. Furniture packed and loaded in a container is not described by that definition. Section 149.1(d) separately defines break bulk cargo as cargo that is not containerised but is packaged or bundled, and §149.4(b) relaxes the timing for it.
That is a plain reading of the definitions. If a shipment is part container and part loose cargo, or if the vessel call has unusual features, ask the broker to confirm which provisions apply before the booking is made.
The ten data elements
Section 149.3(a) lists ten elements for shipments intended to be entered into the United States. They are provided for each good listed at the six-digit HTSUS number at the lowest bill of lading level, which the text describes as the house bill of lading level where there is one. The manufacturer (or supplier), country of origin and commodity HTSUS number must be linked to one another at the line item level.
| # | Element in §149.3(a) | What the text says | Question to settle |
|---|---|---|---|
| 1 | Seller | Name and address of the last known entity by whom the goods are sold or agreed to be sold. If the goods are not imported by purchase, the name and address of the owner. | Which company is the last seller named for this container? |
| 2 | Buyer | Name and address of the last known entity to whom the goods are sold or agreed to be sold, or the owner if the goods are not imported by purchase. | Which company is the last buyer named for this container? |
| 3 | Importer of record number | The IRS number, Employer Identification Number, Social Security Number or CBP-assigned number of the entity liable for payment of all duties and responsible for meeting all statutory and regulatory requirements incurred as a result of importation. | Which entity is liable for duties on this container, and does it hold one of the listed numbers? |
| 4 | Consignee number(s) | The same kinds of number, for the individuals or firms in the United States on whose account the merchandise is shipped. | On whose account is the merchandise shipped, and what number does that party hold? |
| 5 | Manufacturer (or supplier) | Name and address of the entity that last manufactures, assembles, produces or grows the commodity, or of the party supplying the finished goods in the country from which the goods are leaving. | Which name and address will be entered for each good? |
| 6 | Ship to party | Name and address of the first deliver-to party scheduled to physically receive the goods after release from customs custody. | Where does the container go after release, and who receives it? |
| 7 | Country of origin | Country of manufacture, production or growth, based upon the import laws, rules and regulations of the United States. | Which country applies under United States rules for each good? |
| 8 | Commodity HTSUS number | The number under which the article is classified in the Harmonized Tariff Schedule of the United States, provided to the six-digit level and permitted up to ten digits. | Which six-digit number applies to each good on the container? |
| 9 | Container stuffing location | Name and address of the physical location(s) where the goods were stuffed into the container. | Where will the goods be stuffed into the container? |
| 10 | Consolidator (stuffer) | Name and address of the party who stuffed the container or arranged for the stuffing of the container. | Who stuffs the container, or arranges for it to be stuffed? |
For the commodity number, the text says the number must be given to six digits and may be given up to ten, and that it can be used for entry purposes only if provided at the ten-digit level or greater by the importer of record or its licensed customs broker. Our note on HS Chapter 94 for contract furniture sets out how the Chapter 94 headings read: 9401 for seats, 9403 for other furniture and 9404 for mattress supports and articles of bedding. Because the elements are given per six-digit number, a container that carries seating, casegoods and mattresses together carries more than one line, and each line needs its manufacturer or supplier, country of origin and number linked.
Planning a container to the United States?
Send your FF&E schedule and the destination. Our team will review it and get back to you.
When each part is due
Section 149.2(b) gives three time points. They are tied to loading at the foreign port and to arrival, not to the date of the purchase order.
| Data | Deadline in §149.2(b) |
|---|---|
| Seller, buyer, importer of record number and consignee number(s) | No later than 24 hours before the cargo is laden aboard the vessel at the foreign port. |
| Manufacturer (or supplier), ship to party, country of origin and commodity HTSUS number | No later than 24 hours before the cargo is laden aboard the vessel at the foreign port. |
| Container stuffing location and consolidator (stuffer) | As early as possible, and in no event later than 24 hours prior to arrival in a United States port, or upon lading at a foreign port that is less than a 24-hour voyage from the closest United States port. |
Two features of the timing matter to a project schedule. First, the first deadline runs from lading in China, so the party names, the importer of record number and the six-digit numbers have to be settled before the container is loaded. Second, §149.2(f) allows a flexible approach for the four elements in §149.2(b)(2): the filer may give an initial response based on the best data available at the time, and must update as soon as more precise or accurate information is available, and in no event less than 24 hours prior to arrival at a United States port.
Verification, updates and withdrawal
Section 149.2(c) addresses a filer that receives information from another party. CBP will take into consideration how, in accordance with ordinary commercial practices, the presenting party acquired the information and whether and how it can verify it. Where the filer is not reasonably able to verify, the text permits it to present the information on the basis of what it reasonably believes to be true.
Section 149.2(d) requires the party who submitted the filing to update it if, after submission and before the goods enter the limits of a United States port, any of the information changes or more accurate information becomes available. Section 149.2(e) requires withdrawal, with the reason transmitted to CBP, if the goods associated with a filing are no longer intended to be imported to the United States. On a furniture order these provisions bear on changes between booking and sailing, such as a container split, a change of ship to party or a corrected number, which should reach the filer with enough time for the update to be made.
Bonds and authorised agents
Section 149.5 sets conditions for filing. Under paragraph (a), a party must establish the communication protocol CBP requires for presenting the filing through the approved data interchange system. Under paragraph (b), the ISF Importer must hold one of the bonds the text lists, which include a basic importation and entry bond and an importer security filing bond under Appendix D to Part 113. If the ISF Importer does not have a required bond, the agent who submits the filing on its behalf may post the agent’s bond. Under paragraph (c), authorised agents must retain powers of attorney in English until revoked, and must retain revoked powers of attorney and letters of revocation for five years after revocation.
Section 149.6 adds that where the filing is sent in the same electronic transmission as entry or entry summary documentation, the importer of record number, consignee number, country of origin and, if given at ten digits, the commodity number need be provided only once.
What this means for a furniture schedule
The text is addressed to the ISF Importer and its agent, but the data comes from the project: the party names, the numbers, the goods and the loading arrangements. The points below can be settled while the order is still being specified.
- Name the ISF Importer. Decide which entity acts as ISF Importer and which licensed customs broker or other authorised agent will transmit the filing, and confirm the power of attorney is in place.
- Fix the numbers per line. For each product group on the container, settle the six-digit number and the country of origin under United States rules before the loading date is set.
- Settle the parties. Confirm the seller and buyer named on the commercial documents, the importer of record number, the consignee number(s) and the ship to party.
- Ask where and by whom the container is stuffed. The stuffing location and the consolidator are elements in their own right, so the loading plan needs to name them.
- Keep changes moving. Agree how a change after booking, such as a split container or a corrected number, will be passed to the filer.
How this sits with an FBM Furniture order
FBM Furniture quotations are EXW as standard, C&F on request, and DDP for certain markets such as the United States. Customs clearance and inland transportation at the destination are handled by the customer unless DDP is quoted, and the proforma invoice records the trade term and the estimated dates for the order. Our glossary of contract furniture sourcing terms explains the trade terms. If a quotation is DDP, ask in writing who will act as the ISF Importer and who will file, since the text allows an authorised agent to transmit the filing.
FBM Furniture arranges container loading, sea freight and documents, normally with its own forwarder, and sends a loading report; if you nominate a forwarder, it books with it. The note on what arrives with a contract furniture shipment describes the QC report, loading report and shipping documents. For the wider customs picture on the main site, FBM Sourcing’s note on who clears customs on a project import sets out the roles of importer, broker and agent.
Source and date
This article reads 19 CFR Part 149, Importer Security Filing, as published on the Electronic Code of Federal Regulations, current as of 19 October 2026 and read on 21 October 2026. Regulations are amended; check the current text and CBP’s own instructions before you rely on any date or data element above.
Frequently asked questions
Who files the Importer Security Filing for a container of furniture?
Section 149.2(a) says the ISF Importer or an authorised agent must submit the filing. Section 149.1(a) describes the ISF Importer as the party causing goods to arrive within the limits of a United States port by vessel, and for most shipments as the goods’ owner, purchaser, consignee or an agent such as a licensed customs broker.
What data does the filing ask for?
Ten elements under §149.3(a): seller, buyer, importer of record number, consignee number(s), manufacturer (or supplier), ship to party, country of origin, commodity HTSUS number, container stuffing location and consolidator (stuffer).
When is the filing due?
Eight of the ten elements are due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port. Container stuffing location and consolidator are due as early as possible and no later than 24 hours prior to arrival in a United States port.
Does the filing apply to every container?
Section 149.2(a) applies to cargo arriving by vessel and excepts bulk cargo under §149.4(a). Bulk cargo is defined in §149.1(c) as cargo stowed loose in the hold and not enclosed in any container. Your broker confirms how the text applies to a particular shipment.
Can the data be corrected after it is submitted?
Yes. Section 149.2(d) requires the filer to update the filing if the information changes or more accurate information becomes available before the goods enter a United States port, and §149.2(e) requires withdrawal if the goods will no longer be imported.
Who files if FBM Furniture quotes DDP?
The text allows an authorised agent to transmit the filing for the ISF Importer. If a quotation is DDP, ask in writing who will act as the ISF Importer and who will file.
Planning a container to the United States?
Send your FF&E schedule and the destination. Our team will review it and get back to you.