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CTPAT

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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 |2026-11-11T17:46:39-05:00November 11, 2026|ACE, CTPAT, Customs Broker, U.S. Customs and Border Protection (CBP)|0 Comments
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CBP Will Require Foreign Importers of Record to Be CTPAT-Validated or Use a CTPAT-Validated Broker Beginning January 5, 2027 

U.S. Customs and Border Protection (CBP) released an interim final rule on November 5, 2026 under which a foreign importer of record must be validated under the Customs Trade Partnership Against Terrorism (CTPAT), or use a CTPAT-validated customs broker, to file formal and informal entries beginning January 5, 2027. The rule implements Executive Order 14411, Strengthening Customs Enforcement. Foreign companies that import in their own name, the U.S. buyers that depend on them, and customs brokers that are not CTPAT-validated each need a plan before January 5. 

Key Takeaways 

  • Beginning January 5, 2027, CBP will require a foreign importer of record to be validated under the Customs Trade Partnership Against Terrorism (CTPAT), or to use a CTPAT-validated customs broker, in order to file formal and informal entries. 
  • The rule treats any importer of record that does not meet its definition of a U.S. importer of record as a foreign importer of record. That definition turns on U.S. citizenship or lawful permanent residency, U.S. organization and location, U.S. beneficial ownership and control, or direct ownership of a significant amount of unencumbered U.S. real property.

  • The rule will require all licensed customs brokers to verify whether each client qualifies as a foreign or U.S. IOR before filing an entry. This applies to every broker, not just CTPAT-validated ones.
By |2026-11-06T11:13:23-05:00November 5, 2026|CTPAT, Customs Broker, Enforcement, U.S. Customs and Border Protection (CBP)|0 Comments
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2026 CBP Trade and Cargo Security Summit: Key Takeaways for Importers 

U.S. Customs and Border Protection (CBP) brought together government officials and members of the trade community in Dallas from September 8–10, 2026, for its annual Trade and Cargo Security Summit (TCSS). This year’s theme “Knowing Your Supply Chain to Remain Compliant and Mitigate Risk” was reflected throughout three days of discussions on enforcement, supply chain visibility, artificial intelligence, forced labor, transshipment, CTPAT, cybersecurity, and the future of customs compliance.  

Here are some of the most important takeaways for importers.

  1. CBP Is Entering a New Era of Customs Enforcement

A major focus of the Summit was the Administration’s June 3, 2026 “Strengthening Customs Enforcement” Executive Order and the regulatory changes expected to follow. 

The Executive Order calls for, among other things, heightened requirements for Importers of Record (IORs), expanded data and identification requirements, and increased vetting of IORs and other parties throughout the import process. CBP officials emphasized that implementation will be an agency-wide effort and that additional regulatory packages are expected.  

The shift is already visible in the government’s broader enforcement posture. Discussions at the Summit emphasized customs fraud, shell companies, identity theft, false importer information, double invoicing, and other schemes CBP is encountering in the trade environment. CBP also stressed that its focus is not on ordinary clerical mistakes, but on identifying and escalating consequences for parties intentionally exploiting the system.  

  1. Supply Chain Visibility Is Becoming a National Security Issue

Perhaps no […]

By |2026-09-18T12:55:53-04:00September 18, 2026|Best Practices, CTPAT, Enforcement, Forced Labor, Import, Supply Chain, U.S. Customs and Border Protection (CBP)|0 Comments
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CBP Wants Your Foreign Export Documents: What the Supply Chain Visibility ANPRM Means for Importers

On September 2, 2026, U.S. Customs and Border Protection published an advance notice of proposed rulemaking that would fundamentally change what importers must know, keep, and disclose about the parties behind every shipment entering the United States. The notice implements Section 3 of Executive Order 14411 and covers foreign export documentation, replacement of the manufacturer identification code, foreign tax and global business identifiers, supply chain tracing technology, and expanded CTPAT requirements. Comments are due December 1, 2026, and the questions CBP is asking tell importers exactly where enforcement is headed. 

KEY TAKEAWAYS 

  • CBP published an advance notice of proposed rulemaking on September 2, 2026 (Docket No. USCBP-2026-1058) that would give the agency visibility into every party in an import supply chain, from the foreign factory to the final delivery address. 
  • The headline proposal: importers of record may be required to obtain, retain, and submit the export declaration, invoice, packing list, and other documents their foreign supplier filed with its own customs authority. CBP says the purpose is to catch dual invoicing and undervaluation. 
By |2026-09-23T09:54:28-04:00September 2, 2026|CTPAT, Supply Chain, U.S. Customs and Border Protection (CBP)|0 Comments
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CBP Just Rewrote the Forced Labor Rulebook: What the New Operational Guidance Means for Importers

Short summary: On June 9, 2026, CBP issued new guidance supplementing its 2022 UFLPA guidance and other resources with a single document covering every forced-labor authority it enforces. The new guidance outlines CBP’s detention and exclusion processes and gives practical guidance on how to respond.

On June 9, 2026, U.S. Customs and Border Protection (CBP) published its new Forced Labor Enforcement Operational Guidance for Importers (Publication No. 5560-0526). It is not a refresh. It updates the June 13, 2022, UFLPA Operational Guidance for Importers and, for the first time, consolidates all forced-labor enforcement authorities CBP wields into a single 89-page reference. 

That consolidation is the story. Until now, importers had to stitch together separate sources to understand how the Uyghur Forced Labor Prevention Act (UFLPA), Withhold Release Orders and Findings under 19 U.S.C. § 1307, and the Countering America’s Adversaries Through Sanctions Act (CAATSA) actually differ in practice. CBP has now mapped all of them — including the exact timelines, the review paths, and the documentation bar — in one place. The practical effect: ignorance of the process is no longer a defensible position. 

The one-line summary every importer needs 

CBP detains or excludes goods it suspects were made, wholly or in part, with forced labor — and the burden is on you to prove they weren’t, on a clock that can […]

By |2026-06-17T10:00:59-04:00June 17, 2026|CTPAT, Enforcement, Forced Labor, Import, International Trade, U.S. Customs and Border Protection (CBP)|0 Comments
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