ACE Archives - Customs & International Trade Law Firm

CBP Releases Foreign IOR Overview, Reference Guide, and Broker Delayed Compliance Form
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CBP Releases Foreign IOR Overview, Reference Guide, and Broker Delayed Compliance Form
ACE, CTPAT, Customs Broker, U.S. Customs and Border Protection (CBP)

CBP Releases Foreign IOR Overview, Reference Guide, and Broker Delayed Compliance Form

U.S. Customs and Border Protection (CBP) has published three implementation documents for its Heightened Requirements for Foreign Importers of Record interim final rule: a one-page Overview, a three-page Reference Guide on U.S. importer of record (IOR) status, and a Broker Delayed Compliance Request Form.

Together they set out which records CBP lists for verifying U.S. IOR status, the new entry data fields, and the steps a customs broker must take to request delayed compliance before January 5, 2027. Foreign IORs, U.S. companies that rely on them, and every licensed customs broker filing entries for clients that claim U.S. IOR status are affected.

KEY TAKEAWAYS

CBP issued a one-page Overview, a three-page Reference Guide, and a Broker Delayed Compliance Request Form alongside the Heightened Requirements for Foreign Importers of Record interim final rule (91 FR 69977, November 6, 2026).
CBP’s Overview notes that, currently, only Canadian foreign importers of record (IORs) are eligible for CTPAT validation. A foreign IOR that is not CTPAT validated must designate a CTPAT validated licensed customs broker to make entry.
The Reference Guide lists the records brokers or CBP may use to verify U.S. IOR status, including passports, Secretary of State records, shareholder ledgers, and deeds, plus examples for verifying physical domestic assets.
Brokers seeking delayed compliance must email the completed form to […]

By Jennifer Diaz|2026-11-11T17:46:39-05:00November 11, 2026|ACE, CTPAT, Customs Broker, U.S. Customs and Border Protection (CBP)|0 Comments

Postal De Minimis Rule Update: CBP Makes the January 20, 2027 Mail Entry Deadline Official and Eases PGA Data for Entry Type 13
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Postal De Minimis Rule Update: CBP Makes the January 20, 2027 Mail Entry Deadline Official and Eases PGA Data for Entry Type 13
ACE, Customs Broker, U.S. Customs and Border Protection (CBP)

Postal De Minimis Rule Update: CBP Makes the January 20, 2027 Mail Entry Deadline Official and Eases PGA Data for Entry Type 13

U.S. Customs and Border Protection (CBP) published a final rule in the October 22, 2026 Federal Register that moves the compliance date for the postal rule’s formal entry requirements from October 22, 2026, to January 20, 2027. The same day, CBP modified its Entry Type 13 test so filers can submit an electronic mail entry before their Partner Government Agency (PGA) data is complete. Importers, e-commerce sellers, and licensed customs brokers handling mail shipments subject to PGA requirements, Chapter 98 or 99 duties, or Chapter 98 and free trade agreement claims now have a published date and a lower barrier to start filing Entry Type 13.

Key Takeaways

On October 22, 2026, CBP published a final rule setting January 20, 2027, as the compliance date for the postal formal entry provisions in 19 CFR 145.12(a)(2)(v) and (vi) (91 FR 66638).
The rule covers mail shipments subject to Partner Government Agency (PGA) requirements, subject to duties under HTSUS Chapter 98 or 99, or claiming duty-free treatment under Chapter 98 or a free trade agreement.
CBP stated that the extension does not change the process currently used for informal mail entries during the delay, and that parties may come into compliance earlier.
In a separate notice effective October […]

By Jennifer Diaz|2026-10-23T16:10:52-04:00October 23, 2026|ACE, Customs Broker, U.S. Customs and Border Protection (CBP)|0 Comments

CBP Proposes Bonds and Earlier Filing for Low-Value Informal Entries: Comments Due December 7
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CBP Proposes Bonds and Earlier Filing for Low-Value Informal Entries: Comments Due December 7
ACE, Customs Broker, Import, U.S. Customs and Border Protection (CBP)

CBP Proposes Bonds and Earlier Filing for Low-Value Informal Entries: Comments Due December 7

U.S. Customs and Border Protection (CBP) has issued a Notice of Proposed Rulemaking (NPRM) for Low-Value Shipments that would change informal entry requirements for shipments valued at $2,500 or less, including shipments arriving through international mail. The proposal would add a bond requirement for informal entries, move the Type 11 filing deadline earlier, and create a new electronic Entry Type 13 for mail. Importers, e-commerce sellers, licensed customs brokers, and carriers that handle low-value shipments are affected, and comments are due December 7, 2026.

Key Takeaways

CBP proposes that all Type 11 (informal) and new Type 13 (informal mail) entry filers obtain a basic importation and entry bond, single transaction or continuous, before release.
The proposed Type 11 filing deadline moves from “within 15 calendar days after landing,” to “upon or before the date of importation”, and Type 11 entries would be filed electronically.
A new Entry Type 13 for international mail of $2,500 or less would be filed electronically by the owner or purchaser in ACE or by a licensed customs broker.
Carriers filing inward manifests would report the mail tracking number, and unentered mail of $2,500 or less would be considered abandoned after 15 days.
Comments are due December 7, 2026, under docket USCBP-2026-0298 on regulations.gov.

Low-Value Shipments Face New Entry Requirements

CBP […]

By Jennifer Diaz|2026-10-09T11:49:46-04:00October 9, 2026|ACE, Customs Broker, Import, U.S. Customs and Border Protection (CBP)|0 Comments

Mandatory CPSC eFiling is Here
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Mandatory CPSC eFiling is Here
ACE, Import, U.S. Consumer Product Safety Commission (CPSC)

Mandatory CPSC eFiling is Here

Key Takeaways

Starting July 8, 2026, importers of most regulated consumer products must electronically file (eFile) Certificate of Compliance data into CBP’s ACE system at the time of entry, no longer on request.
At launch, CPSC does not intend to have ACE reject entries or deny admission solely for failure to eFile, only warning messages. But CPSC will still enforce certificate requirements, seek seizure of non-compliant goods, and adjust your risk score.
A testing exemption or determination does not eliminate the certificate. You must still issue a certificate citing the rule and naming the exemption. This is a trap that catches importers who assume “exempt” means “nothing to file.”
Products entering a Foreign Trade Zone and later withdrawn for consumption or warehousing get a later effective date: January 8, 2027.
The eFiling rule changes how certificate data is filed, not which products need a certificate. Certification has been required since 2008.

A Compliance Shift Disguised as a Filing Update

Since 2008, importers and domestic manufacturers of CPSC-regulated consumer products have been required to maintain a Certificate of Compliance: a Children’s Product Certificate (CPC) for children’s products, or a General Certificate of Conformity (GCC) for regulated general-use products, and produce it on request. Under […]

By Jennifer Diaz|2026-07-08T10:11:26-04:00July 8, 2026|ACE, Import, U.S. Consumer Product Safety Commission (CPSC)|0 Comments

CBP CAPE Phase 2 Update: 4.36 Million Entries Fail, Finally-Liquidated Importers Left Out
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CBP CAPE Phase 2 Update: 4.36 Million Entries Fail, Finally-Liquidated Importers Left Out
ACE, Import, tariffs, U.S. Customs and Border Protection (CBP)

CBP CAPE Phase 2 Update: 4.36 Million Entries Fail, Finally-Liquidated Importers Left Out

KEY TAKEAWAYS

CBP has certified roughly $71.06 billion in IEEPA refunds and cleared 18.1 million entries through CAPE — but the headline number hides who is being left out.
4.36 million entries failed CAPE’s entry-level checks. If your entry is finally liquidated beyond CBP’s 90-day reliquidation window, CAPE will not refund it, and the government is fighting to keep it that way on appeal.
Phase 2 (reconciliation-flagged entries) went live June 29, 2026. Finally, liquidated entries remain in dispute at the Federal Circuit (No. 26-1898).
The government’s stated position: no refund on finally-liquidated entries unless the importer filed suit at the CIT. Filing preserves your standing while the appeal plays out; it is not a guarantee of recovery.
Three fixable failure reasons: importer/filer mismatch, entry-number errors, and CSV template misalignment are costing importers refunds they are otherwise entitled to.

A $71 Billion Headline That Hides Who Isn’t Getting Paid

On July 1, 2026, CBP filed its latest status declaration in Euro-Notions Florida, Inc. v. United States (CIT No. 25-00595) — the lead case now governing how IEEPA duty refunds are administered through CBP’s Consolidated Administration and Processing of Entries (CAPE) platform. The numbers are large. As of June 29, 2026, CBP reported that CAPE declarations had cleared file validation covering 18.1 million entries, that 15.92 […]

By Jennifer Diaz|2026-07-03T12:33:45-04:00July 3, 2026|ACE, Import, tariffs, U.S. Customs and Border Protection (CBP)|0 Comments

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