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19 CFR (US customs regulations) and CBP guidance

Do I need a customs bond to import from China? Bond, ISF, broker

Do I need a customs bond to import from China? Yes for a formal entry: single vs continuous bonds, ISF 10+2 deadline and penalty, and what a broker files.

Updated 4 September 2026 · 9 min read · Written from the public text of the law; sources at the end.

Yes. A first production run from China almost always needs a formal customs entry, and CBP will not release a formal entry without a customs bond on CBP Form 301 (19 CFR 142.4). If the goods travel by sea you also need an Importer Security Filing (ISF 10+2) transmitted at least 24 hours before the container is loaded in China, and the ISF itself must be backed by a bond. Both are normally arranged by a licensed customs broker, who also files the entry and entry summary under your power of attorney.

Who you are in CBP's records

Three roles appear on your paperwork, and for a first-time seller they are usually the same company:

CBP identifies the IOR by an importer number: your IRS Employer Identification Number, a Social Security Number for a sole proprietor, or a CBP-assigned number. You register it on the Create/Update Importer Identity Form, CBP Form 5106, which your broker submits through ACE; CBP says activation typically takes two business days. Do this first, because the ISF and the bond both need the number.

Do you need a bond?

A bond is required to release any formal entry, so the question is whether informal entry is available. 19 CFR 143.21 allows informal entry for shipments not exceeding $2,500 in value, "except for articles valued in excess of $250 classified in Chapter 99, Subchapters III and IV". Section 301 headings for products of China sit in Chapter 99, Subchapter III, so any Section 301 article worth more than $250 needs a formal entry. On top of that, 19 CFR 143.22 lets CBP require a formal entry for any shipment. In practice: plan for a formal entry and a bond on every production order.

The bond is a contract between you (the principal), a surety company and CBP. Under 19 CFR 113.62 the principal and surety agree to pay duties, taxes and charges, to redeliver goods on demand, to comply with ISF requirements, and to pay liquidated damages when they do not. Sureties sell bonds through brokers; you sign an application and, for a continuous bond, a short financial questionnaire.

Single transaction or continuous

Single transaction bond Continuous bond
Covers One entry at one port All entries at all ports for 12 months, renewing until terminated
Amount (CBP bond guide) Generally not less than the total entered value plus all duties, taxes and fees; 3 times value for restricted goods Minimum $50,000, or 10% of the duties, taxes and fees paid in the previous 12 months, whichever is greater; a new importer is set on estimated duties for the next 12 months and "in no event can the bond amount be less than $50,000"
ISF A separate ISF bond, or the agent's bond, is needed for the ISF Satisfies the ISF bond requirement (19 CFR 149.5(b))
Best for A one-off order, a sample run, air shipments of low value More than a couple of ocean shipments a year, any FBA program you intend to repeat
Cost Priced per entry by the surety, scaled to the bond amount Priced per year by the surety

A single transaction bond sized at value plus duties can be large now that the duty stack on Chinese goods is 20% to 55% of value, and the surety prices it accordingly. The $50,000 continuous bond minimum is the surety's exposure, not your premium. Ask your broker for both quotes on the first shipment.

ISF 10+2 for ocean freight

The ISF is a security screening, not a customs entry, and applies only to cargo arriving by vessel (19 CFR 149.2(a)). The ISF importer or its agent transmits ten data elements; the carrier files two more, hence "10+2".

The ten elements (19 CFR 149.3(a))

# Element Where you get it
1 Seller (name and address) Commercial invoice
2 Buyer (name and address) Your company
3 Importer of record number Your EIN as registered on Form 5106
4 Consignee number Usually the same EIN
5 Manufacturer or supplier (name and address) The factory, which may differ from the trading company that sold to you
6 Ship-to party Your prep center, 3PL or the Amazon fulfillment center "in care of"
7 Country of origin China
8 Commodity HTSUS number Your classification, at least six digits
9 Container stuffing location Factory or consolidator, from the forwarder
10 Consolidator (stuffer) The forwarder's warehouse for LCL

Deadline

Elements 1 to 8 must be transmitted "no later than 24 hours before the cargo is laden aboard the vessel at the foreign port" (19 CFR 149.2(b)). Elements 9 and 10 are due as early as possible and no later than 24 hours before arrival at a US port. Elements 5 to 8 may be filed on the best available information and updated later, but no later than 24 hours before US arrival (149.2(f)); any change before arrival must be filed as an update (149.2(d)).

Count back from the vessel cut-off, not the sailing date; forwarders want the ISF data several days before the container closes.

Who files and under whose bond

The ISF importer may self-file or appoint an agent for each filing; CBP's FAQ confirms the agent need not be a customs broker and may be a foreign freight forwarder, except for a "unified filing" (ISF and entry in one transmission), which must be done by the importer or a licensed US broker. The ISF importer must have a bond: a basic importation bond, a custodial or carrier bond, or a stand-alone ISF bond (19 CFR 149.5(b)). If you have no bond, the agent may post its own, but CBP's FAQ is clear that "the ISF Importer remains ultimately liable for the complete, accurate, and timely ISF filing."

Liquidated damages

The bond conditions in 19 CFR 113.62, 113.63, 113.64 and 113.73 provide for liquidated damages of $5,000 per violation for a late, inaccurate or missing ISF. CBP's mitigation guidelines allow a claim for a first violation to be cancelled on payment of between $1,000 and $2,000, depending on mitigating or aggravating factors. A late ISF also invites an examination, which adds port storage and, for FBA, a missed inbound appointment.

What a licensed broker does, and what you still have to give them

Anyone who transacts customs business on behalf of others must hold a CBP broker license (19 CFR 111.2); an importer acting solely for itself does not. Before a broker can act for you, they must obtain a power of attorney, which they keep on file rather than sending to CBP (19 CFR 141.46).

The broker files or arranges:

You still have to give them:

CBP's guidance for new importers states that "even when using a broker, you, the importer of record, are ultimately responsible for the correctness of the entry documentation presented to CBP and all applicable duties, taxes and fees."

Why a first formal entry normally goes through a broker

Filing your own entry means ACE portal access and an ABI software connection, your own surety relationship, the ISF and entry in the correct format, Chapter 99 headings in CBP's required sequence, and partner agency data sets. Together they are a second job, and a wrong or late filing costs liquidated damages, examinations and storage days. A broker does this daily at every port. Most sellers move to a continuous bond and a standing broker after the first shipment for this reason. The complete list of documents, and who prepares each, is in Documents needed to import from China to the USA.

Timeline from purchase order to delivery (illustrative)

Ocean, first order, West Coast port. The durations are typical planning figures, not rules.

Step When Who
Sign PO, pay deposit, give the factory your invoice and packing list template Day 0 You
Register importer number (Form 5106), sign power of attorney, order bond Days 1 to 10 You and broker
Production Days 0 to 45 Factory
Book freight, send ISF data to the filer About 7 days before vessel cut-off You, forwarder
ISF transmitted At least 24 hours before loading Broker or forwarder
Vessel sails; bill of lading issued Day 50 (example) Carrier
Transit 2 to 3 weeks to the West Coast, 4 to 5 weeks to the East Coast Carrier
Entry filed, partner agency data submitted Up to 5 days before arrival Broker
Arrival, CBP release or exam Day 65 to 70 CBP
Entry summary (Form 7501) and payment Within 10 working days after entry Broker, you
Pickup, prep, delivery to Amazon Days 70 to 85 Trucker, prep center

Air freight cuts production-to-door to about 6 to 8 weeks, removes the ISF and the harbor maintenance fee, and raises freight per unit; the numbers are worked through in Landed cost calculator for Amazon FBA sellers buying from China.

What to keep on file

For 5 years from the date of entry (19 CFR 163.4):

When you receive a liquidated damages claim, the petition deadline is printed on the notice; send it to your broker the day it arrives.

Frequently asked questions

Do I need a customs bond for a first shipment from China?

Yes, if the shipment needs a formal entry, and almost every commercial order from China does: shipments over $2,500, and any article over $250 that carries a Section 301 Chapter 99 heading, cannot use informal entry (19 CFR 143.21). A formal entry is not released without a bond on CBP Form 301 (19 CFR 142.4). Your broker arranges it with a surety.

Single transaction bond or continuous bond?

A continuous bond covers every entry for 12 months at every port and also satisfies the ISF bond requirement; CBP sets it at a minimum of $50,000 or 10% of the previous year's duties, taxes and fees, whichever is greater. A single transaction bond covers one entry and is generally set at the entered value plus all duties, taxes and fees. Sellers expecting more than a couple of ocean shipments a year usually choose continuous.

When is the ISF 10+2 due and what happens if it is late?

Eight of the ten ISF elements must be transmitted no later than 24 hours before the cargo is laden aboard the vessel at the foreign port (19 CFR 149.2). CBP's bond conditions provide for liquidated damages of $5,000 per violation for a late, inaccurate or missing ISF; CBP's guidelines allow a first violation to be settled for $1,000 to $2,000 depending on the circumstances.

Do I have to use a licensed customs broker?

No. An importer may file its own entries. In practice a first formal entry needs ACE filing access, a bond, an ISF, a classification and often partner agency filings, which is why nearly all first-time importers use a broker. You remain responsible for the accuracy of everything the broker files.

What is my CBP importer number?

Normally your IRS Employer Identification Number, registered with CBP on the Create/Update Importer Identity Form (CBP Form 5106). A sole proprietor may use a Social Security Number, and CBP can assign a number to a person without either. CBP says a new importer registration is typically activated within two business days.

How long does a first FBA shipment take from purchase order to delivery?

Illustrative only: 30 to 45 days of production, ISF filed at least 24 hours before loading, two to five weeks on the water depending on coast, entry filed before arrival, release at the port, entry summary within 10 working days after entry, then trucking and prep. Plan around 10 to 12 weeks for ocean and 6 to 8 for air.

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Blank templates built from the public law. Not legal advice, and not a filled-in document.

Sources

This guide is general information written from public statutes and agency materials as of 4 September 2026. Laws and agency rules change, and agencies sometimes read a statute differently from its text. It is not legal, tax or customs advice for your situation. Check the sources above or ask a licensed professional before you rely on it.

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