CBP interim final rule sets CTPAT validation requirements for foreign importers of record
CBP announces heightened requirements for Foreign Importers of Record
CBP has issued an Interim Final Rule under Executive Order 14411, "Strengthening Customs Enforcement," requiring foreign importers of record, or their customs brokers, to be CTPAT-validated, effective January 5, 2027. Licensed customs brokers are responsible for verifying that clients meet the qualifications of a U.S. IOR before filing entries on their behalf. Comments are due on or before January 5, 2027, under docket number USCBP-2026-1387 at regulations.gov, and will be considered in deciding whether to amend, confirm or withdraw the rule after its interim implementation.
From January 5, 2027, customs brokers must verify that foreign IOR clients meet U.S. IOR qualifications and CTPAT validation before filing entries on their behalf.
WASHINGTON— U.S. Customs and Border Protection has issued an Interim Final Rule (IFR) to establish new requirements for foreign Importers of Record (IORs) when bringing goods into the United States. Consistent with Executive Order 14411, “Strengthening Customs Enforcement,” the IFR is designed to strengthen importer accountability, improve CBP’s ability to address noncompliance, and help ensure that all importers operate under clear and enforceable requirements.
“The executive order levels the playing field by holding foreign IORs to the same standards as U.S.-based IORs and requiring them – or their customs brokers – to be CTPAT-validated,” said Diane J. Sabatino, Executive Assistant Commissioner, Office of Field Operations. “This increases transparency, prevents the importation of unlawful and dangerous goods, and ensures fair competition for U.S. businesses and importers.”
These heightened requirements support CBP’s mission to protect the American public and ensure the collection of revenue owed to the United States. By requiring CTPAT validation, CBP is leveraging its trusted trader program to prevent foreign parties from evading U.S. customs and trade laws and leveling the playing field for U.S. businesses.
“Licensed customs brokers are now responsible for verifying that their clients meet the qualifications of a U.S. IOR before filing entries on their behalf,” said CBP Office of Trade Executive Assistant Commissioner Susan S. Thomas. “This requirement ensures that foreign importers are held accountable to U.S. laws which helps mitigate risks to revenue, U.S. industries, American consumers, and national security.”
The IFR becomes effective on January 5, 2027. The public may submit comments through the Federal Rulemaking Portal at www.regulations.gov under docket number USCBP-2026-1387. Comments must be received on or before January 5, 2027, and comments will be considered in determining whether to amend, confirm, or withdraw the rule following its interim implementation.
These efforts support CBP’s broader work to protect the economy of the United States, ensure the health and safety of the American people, and strengthen the security and resilience of international supply chains.
For additional information on the IFR, Executive Order 14411, and related CBP actions, visit CBP's Strengthening Customs Enforcement website. Follow the CBP Office of Trade on LinkedIn and Instagram, and CBP Office of Field Operations on Instagram.
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Source: CBP · Newsroom · cbp.gov