What Importers Should Know About the New Importer of Record Requirements

What Importers Should Know About the New Importer of Record Requirements

U.S. Customs and Border Protection published new Importer of Record requirements on November 6, 2026, with an effective date of January 5, 2027. The changes may affect how certain U.S. and foreign importers enter merchandise into the United States.

U.S. and Foreign Importers

The rule distinguishes between U.S. Importers of Record and Foreign Importers of Record. A U.S. mailing address or U.S. incorporation alone may not establish eligibility under the updated requirements. Importers should review their business organization, location, ownership and control, citizenship or lawful permanent resident status, U.S. assets or real property, and supporting records.

CTPAT Considerations

Foreign Importers of Record may face additional requirements involving CTPAT participation or the use of a CTPAT-validated customs broker. Importers should not assume that every licensed customs broker is CTPAT validated. Confirm current status and determine whether the requirements apply to your transactions.

What Importers Can Do Now

• Review the official rule and applicable requirements.

• Determine whether you may be classified as a U.S. or Foreign Importer of Record.

• Gather ownership, identity, residency, and business documents.

• Discuss questions with a qualified customs professional.

Preliminary Discussions

Sandra De Leon CHB welcomes preliminary questions from importers reviewing their circumstances. An initial inquiry does not confirm eligibility, create a broker-client relationship, or authorize customs business. Any services require a separate review, engagement, and power of attorney.

This article is for general educational purposes only and is not legal advice. Importers should review the final Federal Register text and consult qualified counsel or a customs professional regarding their specific situation. Publication and effective dates should be confirmed against the official notice before relying on them.

Source: U.S. Customs and Border Protection and the Federal Register.