Outdated Trade Regulations – CBP Open to Feedback
Whether you’re a seasoned importer or just entering the trade world, keeping up with thousands of pages of regulations can be a challenge.
A stated priority of the current administration is deregulation. On January 31, 2025, President Trump signed an Executive Order titled “Unleashing Prosperity Through Deregulation.” The Order requires that whenever an agency promulgates a new rule, regulation, or guidance, it must identify at least 10 existing rules, regulations, or guidance documents to be repealed.
At last month’s Trade and Cargo Security Summit, CBP said they and their partner agencies are seeking feedback on what regulations are obsolete or simply don’t reflect the reality of the current trade environment.
Here’s a sampling of some potential obscure and obsolete regulations that CBP may consider revisiting (what are your additions to this list?):
Allowing Non-Resident Importers to Act as an Importer of Record in the U.S.
Although there are many entities that legitimately use the exception found in 19 CFR 141.18, which permits non-resident corporations to make entry of goods into the U.S. (as an importer of record), companies can also do so with malicious intent. The non-resident entity solely needs a U.S. agent for service of process and a customs bond. This particular exception is one that a bad actor can use surreptitiously. For example, a non-resident importer can create a shell […]
