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Trade Policy

CBP tightens foreign importer-of-record rules: CTPAT or a CTPAT broker from Jan. 5, 2027

An interim final rule published Nov. 6 bars most foreign IORs from filing consumption entries unless they are CTPAT-validated or use a CTPAT-validated licensed broker; comments are due the same day the rule takes effect.

By Kwame ·
Row of white refrigerated semi-trailers parked in a gravel lot with city towers behind
Photo: under_volcano · CC BY-SA 2.0

U.S. Customs and Border Protection published an interim final rule on Nov. 6, 2026 that raises the bar for foreign importers of record who want to enter merchandise for consumption.

The rule (CBP Dec. 26-19, RIN 1685-AA48, Federal Register document 2026-22735) amends 19 CFR parts 110, 111, 141, 142 and 171. It carries out Section 2 of Executive Order 14411, Strengthening Customs Enforcement.

Key dates

  • Effective: January 5, 2027
  • Comments: due January 5, 2027 on docket USCBP-2026-1387
  • Broker verification (§ 111.29): brokers may request delayed compliance before January 5, 2027; CBP expects full broker compliance by May 6, 2027

What foreign IORs must do

A foreign importer of record may enter goods for consumption only if it is a CTPAT-validated participant, or if it designates a licensed customs broker who is CTPAT-validated.

A non-validated foreign party must use a CTPAT-validated broker. If the principal on the power of attorney is not the owner or purchaser of the merchandise, that broker must also act as the importer of record on the entry.

U.S. IOR checkbox and broker duties

Updated CBP Forms 3461 and 7501 (and their electronic equivalents) will include a checkbox to declare U.S. IOR status. False declarations can trigger live-entry requirements and the loss of immediate-delivery privileges.

Brokers must verify that a client qualifies as a U.S. IOR before making that declaration, and keep verification records for five years. CBP is also widening when 19 U.S.C. 1592 penalty guidelines can reach brokers.

Why CBP says it matters

CBP cites unpaid bills and weak collection against foreign IORs. As of Feb. 6, 2026, it put unpaid principal bills opened on or after Oct. 1, 2020 for non-CTPAT foreign IORs at $1.01 billion. Audits from Jan. 1, 2020 through Aug. 27, 2026 found $1.16 billion in lost revenue from foreign IORs and collected $35.7 million of that, a 3.1% collection rate versus 15.2% for U.S. IORs.

The full text is on the Federal Register.

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