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Regulatory Radar · United States (CBP) · Customs

CBP foreign importer rule: CTPAT or CTPAT broker from 5 January

Adopted · updated 6 November 2026 · reviewed 12 November 2026 · North America
Next date: 5 Jan 2027

CBP published an interim final rule, 'Heightened Requirements for Foreign Importers of Record', on 6 November 2026. From 60 days after publication (5 January 2027 according to Flexport and ICPA; the rule text uses a placeholder), an importer of record that is not a 'US importer of record' must be CTPAT validated to enter goods for consumption itself, or use a CTPAT-validated customs broker, for formal entries and informal entry types 11, 12 and 13. A US importer of record is a US citizen or permanent resident, or a US-organised entity located in the US that has at least 51% of its controlling beneficial owners as US citizens or residents or owns significant unencumbered US real property; it declares the status on CBP Forms 3461 and 7501 and must prove it on request. Brokers must verify clients' status and keep records for five years, and may ask for delayed compliance with the verification duty; all brokers must comply by 6 May 2027. Informal entries are not banned, but CBP says it may restrict them later and asks for comment; comments are due on the same 60-day date.

For a parcel An entry filed by a foreign importer of record can only be cleared through a CTPAT-validated party from 5 January, so a DDP parcel needs a validated broker, a validated importer or a US importer of record.

Key dates

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Who it hits

Foreign sellers and marketplaces acting as their own importer of recordCustoms brokersExpress integrators filing entries for foreign importersImporters of record owned or controlled from abroad

What to prepare

  • List the US entries that name a foreign importer of record, and ask each broker whether it is CTPAT validated: validation counts, certification does not, and Flexport and AJOT say it can take months
  • Ask your broker how it will verify clients' US importer of record status and whether it will use the delayed compliance period
  • Where a validated route will not be ready by 5 January, consider shifting terms so that a US buyer that meets the definition is importer of record, as Flexport suggests for DDP shippers

Our reading

The rule lands about two weeks before Entry Type 13 becomes mandatory for mail, so foreign sellers that clear through a foreign entity face two changes in January, and brokers that are not CTPAT validated lose the ability to act for them, which should concentrate volume with fewer brokers. The text we read does not say how the rule applies to mail entries filed through foreign posts, and CBP's remark that it may restrict informal entries later is a risk for low-value flows.
End of de minimisUSMCA leash

Sources

  1. Heightened Requirements for Foreign Importers of Record (interim final rule, public inspection copy) · Federal Register (CBP) · 2026-11-06
  2. CBP new requirements for foreign importers of record · Flexport · 2026-11
  3. IORs must be CTPAT-validated or use a CTPAT-validated customs broker beginning January 5, 2027 · AJOT · 2026-11
  4. USMCA Joint Review Tracker (status as of 8 November 2026) · International Compliance Professionals Association (ICPA) · 2026-11-08

Information, not legal advice. Dates come from official texts or quality legal and trade press, and slip often: always check the current text before acting. Back to the full radar.

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