By: Brian Walczyk, Compliance Manager, TradeInsights, LCB, CCS

US CBP published a notice (91 FR 69977) in the Federal Register on November 6, 2026, outlining the new requirements for Foreign Importers of Record. This publication “Heightened Requirements for Foreign Importers of Record” comes from the Executive Order 14411 which the President signed back in June of this year, “Strengthening Customs Enforcement.”

The interim final rule announced that all foreign importers of records (F-IORs) will be required to either be a Customs Trade Partnership Against Terrorism (CTPAT) validated member or use a CTPAT validated and licensed customs broker to enter merchandise for consumption into the U.S. This change is set to become effective on January 5, 2027. See update § 141.21.

U.S. CBP does maintain a listing of CTPAT validated brokers here, of which V. Alexander & Co., Inc. has held its validation since 2007.

The rule defines what it means to be a U.S. IOR and by not qualifying as a U.S. IOR the entity would then qualify as a F-IOR in the new part of Title 19 – see § 110.2. Importantly CBP also provides the definition of a “beneficial owner” and “physical domestic assets” in § 110.1.

U.S. IOR Qualifications:

1. An individual who is a U.S. citizen or lawful permanent resident; or
2. An entity that meets the following requirements:
3. The entity must be located in the U.S.;
4. The entity must be organized under the laws of the U.S.; and
5. Either:
6. At all times, at least 51% of beneficial owner(s) of the entity, must be U.S. citizens or lawful permanent residents and have control of the entity; or
7. The entity must maintain direct ownership of a significant amount of unencumbered real property in the U.S. at all times.

U.S. CBP did provide some guidance on verification elements it may use – the list is not exhaustive – as seen here. They have also published a Foreign Importer of Record Interim Final Rule Reference Guide that can be seen here.

U.S. licensed brokers will be required (§ 111.29), prior to filing entry on behalf of a client, to verify whether their client meets the criteria to be considered a U.S. IOR. V. Alexander will reach out to any of our clients for additional information should it be necessary, but as a CTPAT validated broker we do not envision a disruption to service as a result of this rule.

The rule further states that new entry filing requirements will be required on the form 3461 or 7501 declaring the qualification of the entity as either a U.S. IOR or not (§ 141.22). U.S. CBP has further issued a CSMS # 70381183 on this declaration requirement on the 3461 or 7501.

The changes are set to become effective on January 5, 2027, and are open to the public for comment on the 91 FR 69977 page here.

We will continue to monitor this situation and issue updates as needed. Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website www.valexander.com for updates on this and other topics.