Customs Broker Archives - Customs & International Trade Law Firm

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

CBP Will Require Foreign Importers of Record to Be CTPAT-Validated or Use a CTPAT-Validated Broker Beginning January 5, 2027
Gallery
CBP Will Require Foreign Importers of Record to Be CTPAT-Validated or Use a CTPAT-Validated Broker Beginning January 5, 2027
CTPAT, Customs Broker, Enforcement, U.S. Customs and Border Protection (CBP)

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 Jennifer Diaz|2026-11-06T11:13:23-05:00November 5, 2026|CTPAT, Customs Broker, Enforcement, 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
Gallery
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
Gallery
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

Commerce Restricts Polysilicon Stockpiling Ahead of December 4 Section 232 Tariffs: What Importers and Customs Brokers Need to Know
Gallery
Commerce Restricts Polysilicon Stockpiling Ahead of December 4 Section 232 Tariffs: What Importers and Customs Brokers Need to Know
Customs Broker, Import, tariffs, U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP)

Commerce Restricts Polysilicon Stockpiling Ahead of December 4 Section 232 Tariffs: What Importers and Customs Brokers Need to Know

On September 24, 2026, the Bureau of Industry and Security (BIS) published a temporary final rule at 91 FR 60505 establishing how the Department of Commerce will identify and restrict importers that stockpile polysilicon and polysilicon derivatives (Polysilicon Products) before the Section 232 minimum import prices and tariffs under Proclamation 11052 take effect on December 4, 2026. The rule caps weekly import volumes for new importers of record, creates a waiver process, and reminds customs brokers of their enforcement exposure. Importers of polysilicon, the covered HTSUS 3818 products, solar cells, and solar modules, along with the customs brokers that file their entries, are affected now.

Key Takeaways

BIS published a temporary final rule at 91 FR 60505 on September 24, 2026. It is effective September 22, 2026, through December 3, 2026.
Commerce is monitoring existing importers of record (IORs). An IOR that Commerce determines is importing Polysilicon Products in volumes substantially greater than its historic averages will be prohibited from making further entries of those products prior to December 4, 2026.
New IORs that registered with CBP on or after August 6, 2026, are prohibited from importing above fixed weekly quantities by HTSUS subheading, absent Commerce approval.
Prohibited or restricted companies may apply to Commerce for a waiver at Polysilicon232@bis.doc.gov. Commerce intends to respond within 14 days of receipt.

By Jennifer Diaz|2026-10-06T08:14:29-04:00October 6, 2026|Customs Broker, Import, tariffs, U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP)|0 Comments

12 Next