Foreign Importers on Record into US Subjected to Tough Customs Restrictions

[ABS News Service/06.11.2026]

US Customs and Border Protection has issued an interim final rule aimed at carrying out an executive order calling for strengthened customs enforcement.

The rule would establish new requirements for foreign importers of record when making entry, and corresponding responsibilities for licensed customs brokers with regard to their clients.

The executive order was signed by President Trump back in June.

It directed the Department of Homeland Security and CBP to strengthen several requirements for importers of record by taking steps such as:

· increasing bonding requirements and requiring IORs to maintain at all times a minimum level of tangible domestic assets, bonding, or both;

· subjecting foreign IORs to heightened requirements for formal entry;

· authorizing only US IORs to file informal entry;

· imposing a “good standing” requirement on all IORs and

· increasing vetting procedures for all individuals and entities that conduct activities directly related to the importation of goods.

The interim final rules, scheduled to be published in today’s Federal Register, lays out the new requirements for IORs.

Following the executive order’s directives, the rule prohibits foreign IORs from filing informal entry because, among other reasons, such IORs are not similarly situated to US IORs and may be less familiar with US customs laws. CBP also is instructed to prohibit foreign IORs who have not been vetted by CBP through CTPAT validation from making formal entry, unless they rely on a CTPAT validated broker to file the entry.

CBP said this is necessary to treat all IORs equally based on their individualized circumstances to protect the revenue and strengthen national security. Through CTPAT validation of IORs, CBP is able to ensure proper vetting of foreign IORs that mitigates risks to revenue, domestic industry, American consumers and national security. CTPAT validation allows CBP to pursue effective enforcement against foreign IORs and provides heightened visibility into their corporate structures and supply chains.

The rule prohibits foreign IORs from making informal entry of merchandise for consumption for which a CBP Form 3461 or 7501 must be filed unless the foreign IOR is either a CTPAT validated participant or uses a CTPAT validated and licensed customs broker. To make formal entry, a foreign IOR must also either be a CTPAT validated participant or use a CTPAT validated and licensed customs broker to enter merchandise for consumption. Foreign parties who are not CTPAT validated IORs must designate a licensed customs broker who is a CTPAT validated participant to file entry on their behalf.

A designated licensed customs broker who is a CTPAT validated participant must act as the importer of record for the entry if such foreign parties are not the owner or purchaser of the merchandise being entered.

CBP said it will be monitoring the informal entries filed by foreign IORs and their brokers following the effective date of the rule. If CBP determines that informal entries filed by foreign IORs present risks to the revenue, national security or public health and safety, CBP will take action to fully prohibit foreign IORs from using informal entry to enter goods for consumption.