U.S. CBP imposes heightened requirements for foreign importers of record
Source
American Shipper
Post Date
11/11/2026
Interim final rule requires foreign importers to comply with CTPAT validation or use a CTPAT-validated broker U.S. Customs and Border Protection (CBP) today issued an interim final rule establishing new requirements for foreign importers of record (IORs) and corresponding responsibilities for licensed customs brokers, consistent with Executive Order 14411, ?trengthening Customs Enforcement.?
Under the interim final rule: ?A foreign IOR generally may enter merchandise for consumption only if the foreign IOR is validated through the Customs Trade Partnership Against Terrorism (CTPAT) program or, if it is not CTPAT validated, uses a CTPAT-validated licensed customs broker to make entry. ?New criteria distinguish U.S. and foreign IORs. A U.S. IOR generally must be either (1) an individual who is a U.S. citizen or lawful permanent resident or (2) an entity organized under U.S. law, located in the United States, that is at least 51% beneficially owned by qualifying U.S. persons or directly owns significant unencumbered U.S. real property. An IOR that does not meet the U.S. IOR criteria is treated as a foreign IOR. ?Licensed customs brokers will have additional responsibilities, including verifying a clients qualification as a U.S. IOR before making the required declaration to CBP and retaining verification records for five years. ?An inaccurate declaration of U.S. IOR status may result in live entry requirements or discontinuance of immediate delivery privileges, and customs brokers that violate 19 U.S.C. 1592 may be subject to penalties under that provision or other available enforcement actions.
The rule is scheduled for publication in the Federal Register on November 6, 2026, and becomes effective 60 days after publication. Comments on the interim final rule are due 60 days after publication.
