CBP Tightens Rules for Foreign Importers of Record: CTPAT Validation Required Starting Jan. 5, 2027
U.S. Customs and Border Protection (CBP) has issued an interim final rule, 'Heightened Requirements for Foreign Importers of Record,' tightening compliance standards for foreign importers of record. Effective Jan. 5, 2027, a foreign importer may serve as importer of record for consumption entries only if it is a validated participant in the Customs Trade Partnership Against Terrorism (CTPAT). A foreign importer that is not CTPAT validated must designate a CTPAT validated, licensed customs broker to make entry on its behalf, and that broker will act as the importer of record for the entry. The rule will be published in the Federal Register on Nov. 6; the pre-publication text has been released under docket number USCBP-2026-1387.
CBP said the rule implements Section 2 of Executive Order 14411, 'Strengthening Customs Enforcement,' signed by the President on June 3, 2026. The rule holds foreign importers of record to the same standards and enforcement mechanisms as U.S. importers, amends Parts 110, 111, 141, 142 and 171 of Title 19 of the Code of Federal Regulations, and sets out corresponding responsibilities for licensed customs brokers acting for their clients, along with consequences for foreign importers and brokers who fail to comply. Foreign importers that are CTPAT validated may continue to file informal entries, but CBP said it will monitor such entries and will move to prohibit them entirely if it finds they present risks to revenue, national security, or public health and safety.
In the rule, CBP said foreign importers present enforcement challenges because their operations and assets are primarily located outside the United States, making it harder to collect unpaid duties, penalties and liquidated damages or to ensure compliance with U.S. customs and trade laws. According to CBP data, non-CTPAT foreign importers accounted for 6.38 seizures per million entry summaries, compared with 1.14 for CTPAT validated foreign importers. Foreign importers file approximately 9 percent of the relevant entry summaries, representing about 23 percent of the value.
For the companion changes affecting customs brokers, CBP will allow licensed brokers to request delayed compliance with the changes to Section 111.29 before the effective date, but all brokers are expected to be in full compliance with the rule no later than May 6, 2027.
Members of the public may submit comments through the federal eRulemaking portal, regulations.gov, under docket number USCBP-2026-1387; comments must be received on or before Jan. 5, 2027, the same day the rule takes effect. Questions may be directed to Anita Rivera of CBP's Trade Programs Directorate at (771) 233-2939 or [email protected].
Source: U.S. Customs and Border Protection
Published by GSM · USA (original Chinese edition)
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