U.S. Customs CBP November 5 new document, "Heightened Requirements for Foreign Importers of Record" interim final rule detailed interpretation, impact analysis and response plan - Shenzhen Topway International Forwarding Co., Ltd.

09/11/2026

Going Global Toolkit | Cross-Border Toolkit

CBTK Compliance Library · IOR Series · Regulatory Interpretation and Response

U.S. Customs CBP

“Heightened Requirements for Foreign Importers of Record” Interim Final Rule

Detailed Interpretation, Impact Analysis and Response Plan

CBP Interim Final Rule — Heightened Requirements for Foreign Importers of Record

Implementing Executive Order 14411 · Effective January 5, 2027

Document Number	CBTK-IOR-2026-018 (provisional)
Document Type	Regulatory interpretation + impact analysis + response plan
Applicable To	Chinese exporting enterprises, cross-border e-commerce sellers, international freight forwarders and customs clearance agents, U.S. licensed customs brokers, cross-border compliance service providers
Subject of Interpretation	CBP Interim Final Rule “Heightened Requirements for Foreign Importers of Record”, FR Doc. 2026-22735, announced 2026-11-05, published in the Federal Register 2026-11-06
Higher Authority	Executive Order 14411 “Strengthening Customs Enforcement” (2026-06-03, 91 FR 35125) §2(b), §2(c), §4, §10
Version / Date	V1.0 · November 5, 2026 (U.S. Mountain Time)
Prepared By	Going Global Toolkit / amtikbay LLC Compliance Research Team

Preparation Notes

This document is prepared based on the authoritative industry summaries (Sandler, Travis & Rosenberg, etc.) of the Federal Register pre-publication draft (81 pages) announced on November 5, 2026, and CBP’s previously released supporting documents for EO 14411. The main text of the rule was officially published on November 6; for items marked “pending verification against the original text” in this document, please refer to the published text. This document is compliance research material and does not constitute legal advice; for decisions involving specific transaction structures, please combine the opinions of licensed customs brokers and U.S. trade attorneys.

Table of Contents

I. Executive Summary 3

1.1 Three-sentence judgment for Chinese enterprises 3

1.2 Overview of key dates 3

II. Basic Document Information and Positioning 4

2.1 Document Elements 4

2.2 What is an “interim final rule,” and why it matters 5

2.3 Position in the EO 14411 implementation roadmap 5

III. Article-by-article interpretation of the core content of the rule 5

3.1 Statutory definition of “U.S. IOR” 5

3.2 Definition of foreign IOR and entry restrictions 7

3.3 New obligations for customs brokers 8

3.4 Penalties and enforcement tools 9

3.5 Matters not covered by this rule and still pending subsequent rules 9

3.6 Alignment with the existing regime 10

IV. Impact analysis 10

4.1 Impact matrix by type of entity 10

4.2 Key judgment one: Chinese-owned U.S. companies = foreign IOR, with no exceptions 11

4.3 Key judgment two: the door to CTPAT self-validation is closed to Chinese companies, and CVCB capacity becomes a scarce resource 11

4.4 Key judgment three: the customs broker market will stratify, and non-CTPAT customs brokers will “purge” foreign clients 11

4.5 Key judgment four: the self-held IOR model still stands, but the compliance threshold is raised 11

4.6 Overlapping timeline risks 12

4.7 Cost impact (qualitative) 12

V. Response plans 12

5.1 General principles: three don’ts, three dos 12

5.2 Chinese companies that already have a U.S. company IOR: 60-day action checklist 13

5.3 Companies that have not yet established an IOR: path selection 13

5.4 International freight forwarders and customs clearance agents: business model transformation 14

5.5 U.S. customs brokers (partners): key points of the verification SOP 14

5.6 Direction of adjustments to the compliance service system (from the service provider’s perspective) 14

5.7 Recommendations for submitting comments (Comment) 15

VI. Implementation timetable and milestones 15

VII. Frequently Asked Questions (FAQ) 16

VIII. Appendices 17

Appendix A: Glossary 17

Appendix B: U.S. IOR eligibility self-assessment form 17

Appendix C: CVCB due diligence document checklist (foreign IOR) 18

Appendix D: Information sources and regulatory citations 18

I. Executive Summary

One-sentence positioning:On November 6, 2026, U.S. Customs and Border Protection (CBP) published in the Federal Register the Interim Final Rule (IFR) “Heightened Requirements for Foreign Importers of Record,” implementing for the first time in regulatory form the restrictions of EO 14411 on Foreign Importers of Record (Foreign IOR): starting January 5, 2027, importers that do not meet the statutory standard for a “U.S. IOR” must themselves pass CTPAT validation, or entrust a CTPAT-Validated Customs Broker (CVCB) to handle import customs clearance; customs brokers must proactively verify whether a client is a U.S. IOR, and if the verification fails and the broker itself is not CTPAT-validated, it may not continue to handle customs clearance for that client.

Five core points

1. The “U.S. IOR” standard is quantified for the first time.The entity must be established under U.S. law, located within the United States, and at all times satisfy: at least 51% of beneficial owners are U.S. citizens or lawful permanent residents and actually control the entity; or directly hold a substantial amount of unencumbered U.S. real property.

2. Foreign IOR is a catch-all definition.Any entity that does not meet the U.S. IOR standard is a foreign IOR—U.S. LLCs and INCs wholly owned or controlled by Chinese natural persons or Chinese companies all fall into this category.

3. There are only two customs clearance paths.Self CTPAT verification, or customs clearance through CVCB. The CTPAT importer category is currently open only to U.S. importers and Canadian non-resident importers, so Chinese companies effectively have only the CVCB path left.

4. Customs brokers become statutory “gatekeepers.”They must obtain and review client materials to verify U.S. IOR identity; penalties for customs brokers expand from the $30,000 cap under 19 USC 1641 to the domestic value of the goods under 19 USC 1592.

5. This is only the “first cut.”The minimum U.S. asset/bond threshold, continuous bond restrictions, good standing, IOR registry tiering, and periodic re-review have not yet been issued; the EO requires implementation by November 30, 2026, and these are expected to be introduced through subsequent rules.

1.1 Three-sentence assessment for Chinese companies

•Models such as “shell borrowing, affiliation, shared IOR, and dual-clearance tax-inclusive” will be directly blocked at the customs broker verification stage.Starting January 5, 2027, once a non-CTPAT customs broker verifies that a client is a foreign IOR, it must stop filing; CVCB, meanwhile, must conduct look-through due diligence on clients, and the space for freight forwarders to “pool IORs” is institutionally compressed.

•The model of holding a U.S. company as the IOR still holds, but it must be truthfully declared as a foreign IOR, and CVCB must be secured in advance.A U.S. company controlled by Chinese capital will not become a U.S. IOR merely because it is “registered in the United States”; using a nominee U.S. shareholder to create 51% ownership constitutes false declaration.

•The biggest practical risk is not the rules themselves, but the scarcity of CVCB capacity and customs brokers “de-risking” by turning away clients.The number of CTPAT-verified customs brokers nationwide is limited; with peak season overlapping the rule effective window, high-quality CVCB will prioritize clients with complete materials and clean structures.

1.2 Key dates at a glance

Date	Item	Significance for companies
2026-11-05	IFR sent to the Federal Register for public display (FR Doc. 2026-22735, 81 pages)	Rule content finalized
2026-11-06	IFR officially published	60-day effective countdown begins
2026-11-30	180-day milestone of EO 14411	Follow-on rules such as assets/bonds, good standing, and registry expected to be issued
2026-12-01	Supply chain visibility ANPRM (Docket USCBP-2026-1058) comment deadline	Topics such as exporting-country documentation and CTPAT expansion
2026-12-07	Low-value shipment NPRM (Docket USCBP-2026-0298) comment deadline	Type 11/13 bonds and IOR identity
2027-01-05	This IFR takes effect; comment deadline; deadline for customs brokers to apply for delayed compliance	Foreign IORs must clear customs via CTPAT or CVCB
2027-05-06	Final deadline for full customs broker compliance	Verification obligations for all customs brokers with no exceptions
2027-07-01	Statutory termination of de minimis ($800 duty-free) (OBBBA)	Low-value imports fully enter formal/informal customs clearance

II. Basic Document Information and Positioning

2.1 Document elements

Element	Content
Document name	Heightened Requirements for Foreign Importers of Record
Issuing agencies	U.S. Customs and Border Protection (CBP), Department of Homeland Security (DHS); some provisions involve countersignature by the Department of the Treasury
Document Nature	Interim Final Rule; request for comments
Federal Register Document Number	FR Doc. 2026-22735; posted 2026-11-05 8:45 AM ET, published 2026-11-06
Length	81 pages in the posted draft (including preamble, regulatory impact analysis, and regulatory text)
Effective Date	January 5, 2027 (60 days after publication)
Comment Deadline	January 5, 2027
Transitional Arrangements	Customs brokers may apply before 2027-01-05 for delayed enforcement of the client verification obligation; all customs brokers must be fully compliant by 2027-05-06
Higher Authority	EO 14411 §2(b) (informal entry by foreign IOR), §2(c) (conditions for formal entry by foreign IOR: CTPAT or CVCB), §4(a) (customs broker accountability), §10 (definitions of U.S. IOR / foreign IOR)
Legal Authority	19 U.S.C. 1484 (entry), 1641 (customs brokers), 1592 (false statement penalties), 1624 (rulemaking authority), etc. (full authority provisions to be verified against the original text)
Regulations Involved	Expected to amend 19 CFR Part 111 (customs brokers), Part 141 (entry), Part 143 (informal entry), etc. (to be verified against the original text)

2.2 What is an “interim final rule,” and why it matters

U.S. federal regulations normally follow the procedure of “Notice of Proposed Rulemaking (NPRM) → public comment → Final Rule.” The interim final rule (IFR) is an exceptional procedure: agencies invoke exemptions based on “good cause” or foreign affairs functions to skip prior comment and directly issue legally binding rules, while simultaneously soliciting comments and retaining the possibility of subsequent revision. The rule by which CBP suspended de minimis on June 24, 2026 also took the IFR form.

There are three implications for businesses:

1.The comment period is not a buffer period.The rule takes effect on January 5, 2027, the same date as the comment deadline; businesses cannot expect the comment process to delay implementation.

2.The text may still be fine-tuned, but the direction will not reverse.CBP has made clear that it will consider public comments in a subsequent final rule; the room to seek improvements is concentrated on technical issues such as quantification of the real property threshold, determination of joint ventures, and the transition period.

3.This is the watershed marking EO 14411’s transition from “policy preview” to “regulatory enforcement.”The earlier CTPAT Alert (August 13) and Form 5106 enforcement notice (August 19) were both administrative measures; this rule is the first formal regulation amending 19 CFR.

2.3 Position in the EO 14411 implementation roadmap

Time	Document / Action	Nature	Status
2026-06-03	EO 14411 “Strengthening Customs Enforcement”	Executive order (top-level design)	Signed
2026-08-13	CBP CTPAT Alert: Due Diligence Standards for CVCB Acting as Foreign IOR	Administrative guidance	Published
2026-08-19	Federal Register Notice: IOR Data Accuracy (91 FR 53627), IOR numbers may be invalidated starting 9-18	Enforcement notice	Implemented
2026-09-02	ANPRM “Heightened Import Disclosures for Supply Chain Visibility”	Advance notice of proposed rulemaking	Comments due 12-01
2026-09-24	This IFR sent to OMB/OIRA for review	Procedure	Completed
2026-10-08	NPRM “Low-Value Shipments” (Type 11/13 bond, prohibition on nominal consignee acting as IOR)	Proposed rule	Comments due 12-07
2026-11-06	This IFR: foreign IOR pathway restrictions + customs broker verification	Interim final rule	Effective 2027-01-05
2026-11-30	EO 180-day milestones: assets/bond, good standing, registry, periodic review	Subsequent rules	Pending issuance
2027-07-01	de minimis statutory termination	Law (OBBBA)	Established

III. Article-by-article interpretation of the core content of the rule

3.1 Statutory definition of “U.S. IOR”

This is the most critical item in the entire text. Previously, EO 14411 §10 only provided a principled definition (“controlling beneficial owners”); this rule quantifies it into verifiable standards:

Entity type	Conditions for becoming a “U.S. IOR”
Individual	U.S. citizen or Lawful Permanent Resident (LPR, i.e., green card holder)
Entity (must satisfy ①②③ simultaneously)	① Organized under the laws of the U.S. (federal or state); ② Located in the U.S.; ③ At all times satisfies one of the following: 　(a)At least 51% of the beneficial owners are U.S. citizens or LPRs, and have control over the entity; or 　(b)Direct ownership of a significant amount of unencumbered real property in the U.S.
Verifying authority	Verified by the Director of the Center of Excellence and Expertise (CEE) with jurisdiction over the importer according to the standards listed in the rule
Declaration obligation	Whether the U.S. IOR eligibility is met must be declared at entry and entry summary
Consequences of false declaration	CBP may require live entry (completion of all declarations and payments before release) and revoke immediate delivery eligibility; in addition, liability for false statements under 19 USC 1592 applies

Key points

“Always” is a hard constraint.The 51% and control requirements must hold at all times. Equity transfers, dilution from capital increases, and director changes can all cause a company to “become” a foreign IOR on a given day, and the declaration obligation applies per entry.

“Beneficial owner + control” is a dual test.A U.S. citizen shareholder holding 51% who does not actually control (for example, where a Chinese party actually operates, signs, and makes decisions) does not satisfy the requirements; and declaring a company actually controlled by a Chinese party as a U.S. IOR constitutes a false declaration.

The real property path is an “alternative path” rather than a “bonus point.”This path does not require a U.S. citizen shareholder, but it requires direct ownership and unencumbered property—properties purchased with a mortgage, held through an affiliate, or leased do not qualify.

Pending verification against the original text

(1) The specific verification standards for “located within the United States”: EO 14411 §10 requires a principal place of business in the United States, a physical presence with substantive business operations, and sufficient tangible assets; the preamble to this rule should provide further detail, which needs to be verified;

(2) Whether “substantial amount” of real property has a monetary threshold (for example, tied to annual import volume or taxes); industry summaries do not disclose this;

(3) The look-through calculation method for “beneficial owner” under trusts, partnerships, and multi-tier shareholding structures;

(4) The trigger method for CEE verification (per-entry spot checks, annual review, or pre-approval before the first entry) and the appeal procedures.

3.1.1 Identity determination for typical shareholding structures

Shareholding / operating structure	Identity determination	Explanation
An LLC / INC established and 100% owned by a U.S. citizen, actually operating in the United States	U.S. IOR	Satisfies all requirements
A U.S. LLC / INC 100% owned by a Chinese natural person	Foreign IOR	Does not satisfy the 51% requirement; being incorporated in the United States does not change the conclusion
A wholly owned subsidiary of a Chinese company (U.S. INC)	Foreign IOR	Beneficial owner looked through to the Chinese shareholder
Sino-U.S. joint venture: U.S. citizen shareholder ≥51% and genuinely controls operations	May be a U.S. IOR	Must undergo CEE verification and be able to prove substantive control (board, signing authority, control of funds)
Sino-U.S. joint venture: U.S. citizen shareholder ≥51% but actually controlled by the Chinese party	Foreign IOR; and there is a risk of false declaration	The “control” requirement is not satisfied; nominee shareholders are a high-risk structure
A Chinese-funded U.S. company directly holding unencumbered factory / warehouse property	May be a U.S. IOR	Depends on the “substantial amount” standard; unrealistic for most trading companies
A Hong Kong / Chinese company directly acting as a non-resident IOR (19 CFR 141.18)	Foreign IOR	Continue to apply the requirements for a resident agent in the state and a U.S. surety company bond
A U.S. customs broker acting as IOR in its own name (for example, as nominal consignee)	If the customs broker itself meets the U.S. IOR conditions, it is a U.S. IOR	This rule clarifies that a POA must still be signed in this case

Risk Alert

It is prohibited to create a “51%” through nominee U.S. shareholder arrangements, holding agreements, or temporary equity arrangements. Such structures simultaneously touch three red lines: false beneficial ownership information on Form 5106 (from September 18, the IOR number can be directly invalidated), false declaration of U.S. IOR status at customs (19 USC 1592, with penalties up to the domestic value of the goods), and termination reports by customs brokers upon discovery during verification (which CBP will use for retroactive action). The core logic of the rule design is “substance over form,” specifically targeting the shell companies, sham transactions, and artificial corporate structures named in EO 14411.

3.2 Definition of foreign IOR and entry restrictions

Definition:Any importer that does not meet the U.S. IOR standard is a foreign IOR (foreign importer of record). This is a catch-all definition; there is no “gray area.”

Core restriction:A foreign IOR may not make entry for consumption under a formal entry or an informal entry unless one of the following is met:

1.It is itself a CTPAT-validated importer;or

2.It engages a CTPAT-validated licensed customs broker (CVCB) to handle customs clearance.

U.S. IORs are unaffected:They may continue to make formal/informal entries under current procedures and may choose a customs broker that is not CTPAT-validated.

The “savings clause” for informal entries:This rule does not immediately prohibit foreign IORs from using informal entries (Type 11, goods valued under $2,500), but instead brings them into the CVCB channel; however, CBP simultaneously states that it will monitor informal entries submitted by foreign IORs and their customs brokers, and once it determines that there are revenue, national security, or public health and safety risks, it will take action to fully prohibit foreign IORs from using informal entries.

Key points

Why Chinese companies have only one path left: CVCB:Under CBP’s current CTPAT eligibility rules, the importer category is open only to U.S. importers and Canadian non-resident importers, and the foreign manufacturer category is also limited to specific countries such as Mexico and Canada; companies in mainland China and Hong Kong cannot apply on their own for CTPAT validation as importers. The option of being “itself CTPAT-validated” in the rule is basically unavailable to Chinese companies, making CVCB the only lawful channel.

Combined effect with the October 8 low-value shipment NPRM:The proposed rule requires bonds for Type 11 informal entries and the new Type 13 mail entries, and prohibits nominal consignees (freight forwarders, carriers) from serving as IOR. Combined, small-value imports by foreign IORs must both go through CVCB and have a bond, fundamentally changing the cost structure.

To be verified against the original text

It is necessary to verify whether this rule provides exceptions or special treatment for the following situations: in-bond transportation, warehouse entry (Type 21), foreign trade zone (FTZ) admission and removal, ATA carnets, temporary importation under bond (TIB), the international mail Type 13 process, and Canada/Mexico highway transportation; and whether the requirement in EO §2(c) that “formal entries by foreign IORs may not rely on continuous bonds” has been written into this rule or left for later.

3.3 New obligations for customs brokers

This rule merges the customs broker accountability requirements in EO 14411 §4(a) and the core ideas of the 2019 shelved proposed rule “Customs Broker Verification of an Importer’s Identity” (84 FR 40302, under TFTEA §116) into mandatory obligations:

#	Obligation	Content	Timing requirement
1	Client eligibility verification	Verify whether the client meets the U.S. IOR standard by requesting and reviewing client records	From 2027-01-05; delay may be requested, no later than 2027-05-06
2	Stop handling customs clearance	If, after verification, the client is determined not to be a U.S. IOR and the customs broker itself has not obtained CTPAT validation, it must stop handling customs clearance for that client	From 2027-01-05
3	CTPAT status requirement	To handle customs clearance for a foreign IOR that is not CTPAT-validated, the customs broker itself must be a CTPAT-validated customs broker; being “licensed” alone is no longer sufficient	From 2027-01-05
4	POA signing	A customs broker must sign a power of attorney when handling any customs business on behalf of a client, even if the customs broker itself serves as the IOR for that shipment	From 2027-01-05
5	Recordkeeping and reporting	In conjunction with the 2022 19 CFR Part 111 modernization rule: verification records, communications records with clients, and reports of service termination (to be verified against the original text for the specific new recordkeeping requirements in this rule)	Continue

Delayed compliance mechanism:Customs brokers may apply to CBP before January 5, 2027, for a delay in the obligation to perform verification; regardless of whether approved, all customs brokers must be fully compliant by May 6, 2027. This mechanism applies to customs brokers, not importers—importers cannot use it to delay switching to CVCB.

Practical recommendations

In conjunction with the August 13 CTPAT Alert, CVCB is expected to verify the following materials when accepting foreign IOR clients: legal identity and registration documents; equity structure and beneficial owners; affiliated enterprises and business relationships; U.S. assets and ability to pay duties and taxes; import and compliance history; information on all parties in the supply chain; basis for commodity classification, valuation, and country of origin. Importers should prepare a “CVCB due diligence package” in advance according to these seven categories (see Appendix C); the completeness of the materials directly determines whether they can be accepted by a high-quality CVCB.

3.4 Penalties and enforcement tools

Penalty basis	Applicable To	Upper limit / standard	Changes in this rule
19 USC 1641	Customs brokers	A maximum fine of $30,000 per violation; suspension or revocation of license, permit	Continues to apply
19 USC 1592	Importers and those who “aid or abet,” now extended to customs brokers	Negligence: 2 times the loss of duties or 20% of the value of the goods; gross negligence: 4 times or 40%; fraud: domestic value of the goods	New:1592 may apply to customs brokers’ violations of this rule
EO 14411 §4(a) + CTPAT Alert	CVCB	Fines, more frequent audits, CTPAT suspension or removal	Obtains a regulatory basis through this rule
This rule (for IOR)	Importers who falsely declare U.S. IOR status	Requires live entry, cancels immediate delivery; combined with the IOR number invalidation mechanism starting September 18	New

The leap from 1641 to 1592 means that the violation cost for customs brokers changes from a “fixed fine” to being linked to the value of the goods. For a customs broker with annual customs clearance value in the tens of millions of dollars, once it is found to have assisted a foreign IOR in evading verification, the theoretical maximum fine is the domestic value of the goods. This is why, after the rule takes effect, customs brokers will proactively “de-risk,” preferring to refuse clients rather than bear pass-through liability.

3.5 Matters not covered by this rule and still pending subsequent rules

ST&R and other institutions clearly pointed out that this rule implements only part of the IOR requirements and restrictions in EO 14411. The following matters still await CBP to be implemented through other rules around November 30:

EO 14411 requirement	This IFR	Expected
All IORs must at all times maintain minimum U.S. tangible assets and/or a bond (§2(a))	Not addressed	Subsequent rule; may be linked to annual import value or duties
Raise the minimum bond coverage level for IORs	Not addressed	Subsequent rule; the current $50,000 continuous bond minimum may be raised
Formal entry by foreign IORs may in principle not rely on continuous bonds unless CBP determines that revenue is adequately protected (§2(c))	Abstract not seen	Pending verification against the original text; if not included, expected to be addressed in the bond rules
Good standing requirement; those not meeting it may not import or designate a customs broker (§2(d))	Not involved	Subsequent rules, involving IOR and related-party compliance history
IOR registry cleanup: remove inactive IORs, classify by risk level	Not involved	Subsequent rules
Enhanced and periodic review of IORs, related parties, customs brokers, freight forwarders, and bonded warehouses	Not involved	Subsequent rules
Expanded disclosures: expected import volume, year established, beneficial ownership, affiliated enterprises, domestic assets, foreign tax ID	Not involved (Form 5106 already has optional fields)	Subsequent rules or Form 5106 revision
Submission of export-country declaration documents (§3)	ANPRM stage	Comment deadline 2026-12-01
Comprehensive ban on informal entry by foreign IORs (§2(b))	Retained as an option CBP can activate at any time	Depending on monitoring results

3.6 Alignment with the existing regime

•19 CFR 141.18 Customs entry by non-resident corporations:A non-resident corporation acting as IOR must still designate a resident agent for service of process in the state where the port of entry is located and submit a bond issued by a U.S. resident surety company; this rule layers CVCB requirements on top of that.

•9-18 Form 5106 accuracy enforcement:IOR name, EIN, actual business address, phone, and email must be truthful and directly associated with the IOR (customs broker, freight forwarder, registered agent, or email service addresses may not be used); these data are the starting point for customs brokers to verify the identity of a U.S. IOR.

•2022 19 CFR Part 111 modernization rule:POA must be signed directly with the IOR (may not be signed through a freight forwarder), customer information must be updated annually, and customs brokers must report to CBP when terminating a client relationship—the verification obligations of this rule build on this framework.

•CTPAT Alert (2026-08-13):Previewed the due diligence standards and consequences of CVCB; this rule provides the regulatory basis for them.

•Low-value shipment NPRM (2026-10-08) and mail Type 13 process:Determines the bond and IOR identity requirements for low-value shipments by foreign IORs, forming a “dual threshold” together with this rule.

IV. Impact analysis

4.1 Impact matrix by type of entity

Entity	Current status (2026)	After 2027-01-05	Impact level
Chinese-controlled U.S. company as IOR (self-held model)	May freely choose any licensed customs broker; most have not declared “foreign IOR” status	Is a foreign IOR; must declare truthfully; may only clear customs through a CVCB; subject to look-through due diligence	High
Hong Kong / Chinese company directly acting as a non-resident IOR	Just configure a resident agent and bond per 141.18	It is a foreign IOR; CVCB is required; the cumulative pressure from subsequent bond rules is the greatest	Extremely high
Freight forwarder “dual clearance and tax-inclusive” / shared IOR / using a U.S. company as a shell	Relies on low-cost non-CTPAT customs brokers and affiliated IORs	After customs broker verification, filing must stop; CVCB does not accept clients with unclear structures; nominal consignees may not serve as IOR (NPRM)	Fatal
Non-CTPAT-verified U.S. customs brokers	Can serve any client	Can only serve U.S. IORs; foreign clients will be lost; the verification system must be completed before 5-06	High
CTPAT-verified customs broker (CVCB)	CTPAT is a competitive advantage	Become the statutory channel for foreign IORs; bear 1592-level liability; proactively screen clients and raise prices	Structurally favorable + increased liability
Amazon / independent site Chinese sellers	Most goods enter under a foreign IOR or freight forwarder IOR	The first-leg customs clearance entity and customs broker qualifications become stockout risk points; the platform has already issued compliance warnings	High
U.S. domestic buyers / importers (DAP, DDU)	As a U.S. IOR, unaffected	Not subject to this rule; but subsequent good standing and asset rules apply	Low
Compliance service providers / IOR establishment service providers	Provide company registration, address, 5106, bond, and customs broker coordination	Services must be upgraded to “foreign IOR compliant declaration + CVCB upfront coordination + look-through documentation system”	High (transformation opportunity)

4.2 Key judgment one: Chinese-owned U.S. companies = foreign IOR, with no exceptions

One of the original intentions of many Chinese companies in setting up U.S. companies is “using a U.S. entity for customs clearance.” This rule makes clear that U.S. registration is only one of the three requirements; if, after look-through of the beneficial owner, the owner is still a Chinese natural person or Chinese company, it is uniformly a foreign IOR. The real property alternative path exists in theory, but after stacking the three qualifiers “directly held + unencumbered + substantial quantity,” it is basically infeasible for trading companies. Therefore, for the vast majority of Chinese-funded U.S. companies, the correct posture is not to “strive to become a U.S. IOR,” but to “truthfully declare foreign IOR status and build a solid CVCB channel.”

4.3 Key judgment two: the door to CTPAT self-validation is closed to Chinese companies, and CVCB capacity becomes a scarce resource

The rule gives foreign IORs two paths, but the first (self CTPAT verification) is constrained by CTPAT’s current eligibility rules, and Chinese companies cannot take it. There are about 2,500 licensed customs brokers nationwide in the United States (based on the CBP TA-015 permitted contact list), of which only a minority have obtained CTPAT verification. After January 5, 2027, all customs clearance demand for foreign IORs will concentrate on this group of CVCBs, and CVCBs will simultaneously bear look-through due diligence responsibility and 1592-level penalty risk, so they will inevitably prioritize clients with complete documentation, clear equity, and clean compliance records, and correspondingly raise service fees and entry thresholds.

Risk warning

Peak-season stacking risk: January 5, 2027 coincides with the pre-Spring Festival shipping peak and the tail end of year-end restocking. If companies wait until December to look for a CVCB, there is a very high possibility of a situation where “the goods arrive at port but no one clears customs,” resulting in demurrage, storage fees, and even forced abandonment of goods. It is recommended to complete CVCB contracting and POA verification before December 15, 2026.

4.4 Key judgment three: the customs broker market will stratify, and non-CTPAT customs brokers will “purge” foreign clients

The rule’s requirement for non-CTPAT customs brokers is rigid: if verification identifies a foreign IOR, filing must stop. Considering 1592 liability, most non-CTPAT customs brokers will proactively terminate foreign clients in early 2027 and report the reason for termination to CBP under Part 111 rules—this means that clients who are cleared out will be flagged by CBP. Companies should proactively change brokers rather than wait for the customs broker to “clear them out.”

4.5 Key judgment four: the self-held IOR model still stands, but the compliance threshold is raised

This rule does not prohibit imports by foreign IORs, but sets “CTPAT or CVCB” admission conditions for them. This is consistent with the direction of the earlier EO 14411: the goal is to ensure that behind every shipment there is an identifiable, accountable, verified importer. For self-held IORs already built according to the principles of “zero affiliation, zero proxy payment, zero false declaration” (real company, real business address, self-held EIN and bond, POA signed directly with the customs broker), the rule brings only two incremental requirements: truthfully declare foreign IOR status, and switch the customs broker to a CVCB. For “fake U.S. IORs” built on affiliation, nominee holding, and false addresses, the rule removes the foundation.

4.6 Overlapping timeline risks

Time window	Overlapping events	Risk points
2026-11-06 to 11-30	IFR publication; EO 180-day milestone rule expected to be issued	If asset/margin thresholds are announced during this period, they will take effect in early 2027 together with this rule
2026-12	Amazon restocking after Black Friday and Cyber Monday; pre-Spring Festival shipping peak	CVCB signing window overlaps with peak season
2027-01-05	This rule takes effect	If the customs broker has not yet switched when in-transit goods arrive at port, they face inability to declare
2027-01-05 to 05-06	Customs broker delayed compliance period	Some customs brokers lag in verification, but importers’ CVCB obligations are not delayed
2027-07-01	de minimis statutory termination	All low-value goods enter the customs declaration system, further amplifying foreign IOR demand

4.7 Cost impact (qualitative)

Cost item	Direction of change	Explanation
Customs brokerage service fee	Rising	CVCB bears due diligence and liability premium; low-cost customs brokers exit the foreign client market
Due diligence document preparation	New	Organization and continuous updating of seven categories of documents including legal identity, equity penetration, U.S. assets, and compliance history
Bond cost	May rise	Not covered by this rule, but subsequent rules may raise minimum coverage or restrict continuous bonds; a per-shipment bond budget needs to be reserved
Informal entry cost	Rising	Type 11 must go through CVCB; NPRM proposes adding a bond; may be fully prohibited at any time
Structural adjustment cost	One-time	Changing customs brokers, re-signing POA, tripartite agreements, 5106 updates
Downtime cost	Risk-related	Port delays, warehousing, abandonment, and order defaults caused by untimely switching

V. Response plans

5.1 General principles: three don’ts, three dos

Compliance principles

Three don’ts:Do not falsely declare U.S. IOR status; do not use nominee shareholders or holding arrangements to manufacture 51%; do not rely on a freight forwarder’s shared IOR or “double clearance and tax-inclusive” service.

Three musts:Must lock in a CVCB and complete the POA before December 15, 2026; must establish and continuously maintain a compliance file according to the seven categories of due diligence materials; must write “foreign IOR declaration” into the SOP for every customs entry.

5.2 Chinese companies that already have a U.S. company IOR: 60-day action checklist

#	Action	Completion indicator	Recommended timeframe
1	Conduct a self-assessment of IOR status (Appendix B): determine item by item according to the three requirements ①②③, and form a written conclusion	Self-assessment form signed and filed	11-15
2	Determine the declaration approach: Chinese-controlled companies must all declare as foreign IOR; notify the customs broker to declare correctly in the entry / entry summary	Written confirmation of the declaration approach from the customs broker	11-20
3	Verify the current customs broker’s CTPAT status: require written confirmation and provide proof of CTPAT account status; immediately initiate replacement of any non-CVCB broker	CTPAT status proof filed	11-20
4	Screen and sign a CVCB: prioritize a CVCB familiar with this product category, with experience serving foreign IORs, and with a clear due diligence process	Service agreement signed	12-15
5	Prepare the CVCB due diligence materials package (Appendix C): Chinese and English versions of the seven categories of materials, with information fully consistent with Form 5106, state registration, and the EIN letter	Materials package delivered and passed CVCB preliminary review	12-10
6	Update the POA: sign directly with the new customs broker; the signatory completes identity verification; a supporting tripartite responsibility agreement clarifies the beneficial owner’s responsibilities	POA verification passed	12-15
7	Form 5106 consistency review: the address is a real business address, and the email and phone are directly under the IOR; beneficial owners and company executives may optionally be filled in	5106 update receipt	11-30
8	Bond assessment: confirm that the continuous bond is valid and coverage is sufficient; communicate in advance with the surety company about the single-entry bond amount and rate	Written reply from the surety company	12-20
9	In-transit cargo scheduling: cargo arriving before 1-05 will complete customs clearance under existing arrangements; all cargo arriving after 1-05 will be declared by the CVCB; avoid cargo being left in limbo across the effective date	Scheduling table	Rolling from 12-01
10	Establish a compliance file: customs declaration documents, due diligence materials, POA, and communication records shall be retained according to CBP’s 5-year追溯 period	File directory	Continue
11	Comments (optional): submit comments regarding the real property threshold, joint venture determination, transition period, etc. (see 5.7)	Submission receipt	Before 2027-01-05

5.3 Companies that have not yet established an IOR: path selection

Path	Legal status	Requirements after 2027-01-05	Applicable scenario	Evaluation
A. U.S. buyer as IOR (DAP / DDU / FOB)	U.S. IOR (buyer)	Not subject to this rule	B2B wholesale, with stable U.S. customers	Lightest; but bargaining power and customer willingness determine
B. Self-owned Chinese-funded U.S. company as IOR	Foreign IOR	Truthful declaration; CVCB customs clearance; look-through due diligence	E-commerce, DDP, own warehousing and distribution	Mainstream compliance path
C. Hong Kong / Chinese company directly acting as non-resident IOR	Foreign IOR	141.18 resident agent and bond + CVCB; greatest pressure from subsequent bond rules	Trial orders, low-frequency imports	Feasible but not recommended for long-term use
D. Genuine joint venture with a U.S. partner (≥51% and genuine control)	May be a U.S. IOR	CEE verification; evidence chain of control	Projects with a genuine U.S. partner	Compliant but high governance cost; nominee arrangements strictly prohibited
E. Freight forwarder “dual clearance and tax-inclusive” / shared IOR	—	Customs brokers stop filing; nominal consignee must not act as IOR	—	Prohibited

5.4 International freight forwarders and customs clearance agents: business model transformation

1.Stop selling “customs clearance included” and “tax included” products.After January 5, 2027, the model of a freight forwarder using its own or borrowed IOR to clear customs for customers will no longer be legally sustainable; continuing to sell it means exposing both customers and yourself to 1592 risk.

2.Transition to an “IOR compliance building + CVCB connection” service provider.Help customers establish and maintain their own IOR, organize due diligence materials, and connect with CVCB, charging service fees rather than assuming import liability.

3.Build a CVCB cooperation network.Select CVCBs by category, port, and service capability, and negotiate in advance the acceptance standards and rates for foreign IOR customers.

4.Revamp quotations and contracts.Clearly state in quotations that the IOR is the customer’s own entity; remove “customs clearance on behalf” clauses from transport contracts; add the customer’s obligation to cooperate with due diligence and liability for breach.

5.Educate customers.Use the timeline of this rule to explain to customers why the switch must be completed by mid-December.

5.5 U.S. customs brokers (partners): key points of the verification SOP

•Customer classification:Label each existing customer one by one as “U.S. IOR / foreign IOR / pending,” and complete verification of pending customers before 2027-05-06.

•Verification checklist:Registration documents, equity structure and beneficial owner proof (identity documents, shareholding proof), evidence of control (articles of association, board resolutions, signature authorization), proof of business address, property ownership (if applicable).

•Records and reporting:Verifier, verification date, verification basis, conclusion; when terminating a customer relationship, report to CBP under Part 111.

•Delayed compliance application:If the existing customer volume is large and verification cannot be completed before 1-05, an application should be submitted to CBP before 1-05, with a plan for completion explained.

•Selection of non-CTPAT customs brokers:Either apply for and obtain CTPAT validation within 2027, or phase out foreign customers; the CTPAT application cycle usually takes several months, so it should be started as early as possible.

5.6 Direction of adjustments to the compliance service system (from the service provider’s perspective)

For service providers whose core product is “compliant IOR setup,” this rule brings an upgrade in service content rather than a rejection of the model. It is recommended to add four supplements to the original process of “company and address → corporate bank account → IOR document package → customs broker coordination → bond → first shipment clearance”:

1.Add an “IOR identity self-assessment and declaration position” module:Issue a written determination based on the three requirements of this rule, clarify that the customer is a foreign IOR, and incorporate the declaration requirements into the first-shipment SOP.

2.Upgrade “customs broker coordination” to “CVCB coordination”:Only coordinate with CTPAT-validated customs brokers; upgrade the CTPAT customs broker list from reference material to a core deliverable, and continuously update it by port, category, and acceptance conditions.

3.Upgrade the “IOR document package” to the “CVCB due diligence document package”:Cover the seven categories of CTPAT Alert materials, aligned item by item with Form 5106, state registration, EIN, and bank account opening information.

4.Upgrade POA and liability documents:Sign the POA directly and complete identity verification of the signatory; a tripartite liability agreement should clearly state that the company and beneficial owners bear all customs liabilities.

At the same time, subsequent rules (assets/security deposit, good standing) should be reserved in product design: at the company formation stage, guide customers to maintain genuine operations, pay taxes on time, and maintain compliance records in preparation for good standing review.

5.7 Recommendations for submitting comments (Comment)

The comment period ends January 5, 2027, and comments should be submitted via regulations.gov under this rule’s docket. Issues of practical significance to Chinese companies and service providers include:

1.“A substantial amount of unencumbered real property” should be set with quantifiable standards (for example, linked to annual tariff obligations or import value), and the assessment method should be clarified;

2.The verification standard for “located within the United States” should be made specific to avoid inconsistent standards across ports caused by CEE discretion;

3.The criteria for determining “control” in joint ventures, and the grace period when equity fluctuates around 51%;

4.Set a transition period for importers corresponding to that for customs brokers, allowing goods already declared before 2027-01-05 to complete customs clearance under the original arrangements;

5.Publish an official searchable list of CTPAT-validated customs brokers, and set temporary arrangements for ports with insufficient CVCB capacity;

6.Clarify the applicability of in-bond, FTZ, warehouse entry, and Type 13 mail processes;

7.Clarify the treatment of Canadian and Mexican importers under the USMCA framework.

VI. Implementation timetable and milestones

Date	Item	Responsible party	Corporate action
2026-11-06	IFR publication	CBP	Download the original text and check the items marked “pending verification against the original text”
2026-11-15	Complete IOR identity self-assessment	Importer	Appendix B
2026-11-20	Confirm customs broker CTPAT status	Importer / freight forwarder	Written proof
2026-11-30	EO 180-day milestone; Form 5106 review completed	CBP / importer	Follow-up rules
2026-12-01	ANPRM comment deadline	CBP	—
2026-12-07	Low-value shipment NPRM comment deadline	CBP	Small-amount import enterprises may submit comments
2026-12-15	CVCB signing, POA verification completed	Importer	Latest deadline
2027-01-05	IFR effective; comment deadline; customs broker delayed compliance application deadline	All	New customs clearance arrangements launched
2027-05-06	Customs broker full compliance	Customs brokers	Confirm that your own file has been verified
2027-06-03	EO 14411 one-year implementation effectiveness report	DHS	Follow policy adjustments
2027-07-01	de minimis statutory termination	Legal	Low-value shipments fully included in customs clearance

VII. Frequently Asked Questions (FAQ)

Q1. My U.S. company is 100% owned by me (Chinese national), registered in Delaware, and the address is a real office. Does this count as a U.S. IOR?

No. The place of registration and a real address only satisfy the first two requirements. The third requirement requires that 51% of the beneficial owners be U.S. citizens or green card holders and actually control it, or directly hold a substantial amount of unencumbered real property. Your company is a foreign IOR and, starting January 5, 2027, must clear customs through CVCB and truthfully declare at the time of customs clearance.

Q2. Then can I find an American friend to hold 51%?

If it is only nominal, no, and it is dangerous. The rules also require “control,” and CEE verification, customs broker due diligence, and Form 5106 beneficial owner information will corroborate one another; once it is determined to be a false declaration, 19 USC 1592 applies, with a maximum penalty based on the domestic value of the goods. Only a joint venture with real capital contribution, real control, and real operations may pass.

Q3. Can foreign IORs still import in the future?

Yes. The rules do not prohibit foreign IORs from importing; they only require that they themselves complete CTPAT verification or clear customs through CVCB. Chinese companies in practice take the latter path.

Q4. My current customs broker is very cheap but does not have CTPAT. Can I wait for it to apply?

Not recommended. CTPAT application and verification usually take several months, and after the rules take effect on January 5, once a non-CTPAT customs broker verifies that you are a foreign IOR, it must stop filing. You should switch to CVCB immediately and not stake your goods on the other party’s application progress.

Q5. Can small shipments under $2,500 still use informal entry?

After these rules take effect, informal entries by foreign IORs must also be handled through CVCB; CBP reserves the right to impose a full prohibition at any time; the proposed rule of October 8 will also require a bond. The cost of small-amount, high-frequency imports will rise significantly and needs to be recalculated.

Q6. Can continuous bonds still be used?

The summary of these rules does not address restrictions on continuous bonds, and existing continuous bonds remain valid. However, EO 14411 §2(c) explicitly requires that, in principle, formal entries by foreign IORs may not rely on continuous bonds. This provision is very likely to be implemented in subsequent bond rules. It is recommended to communicate with the surety company in advance about a single-transaction bond solution.

Q7. What about goods that are at sea on the day the rules take effect?

The determination is based on the entry date, not the loading date. Goods declared on or after January 5 are subject to the new rules. You should ensure that goods arriving after January 5 have been taken over by CVCB and that the POA has been verified.

Q8. Which is better: a Hong Kong company directly acting as a non-resident IOR, or setting up a U.S. company to act as a foreign IOR?

Under these rules, both are foreign IORs and both must go through CVCB. The advantage of a U.S. company lies in bank accounts, platform compliance, and being better able to prove “tangible assets in the United States” under subsequent asset/bond rules; direct import by a Hong Kong company is simpler but faces greater pressure under subsequent rules. For long-term operations, the U.S. company path is recommended.

Q9. The customs broker asks me for shareholder ID documents, articles of association, and bank statements. Is that reasonable?

It is reasonable, and it is required by the rules. CVCB must verify legal identity, beneficial owners, control, and payment ability, and keep records for inspection. The result of refusing to provide information is being denied service.

Q10. Are U.S. domestic buyers as IOR completely unaffected?

This rule does not affect U.S. IORs. However, the asset/bond, good standing, and periodic review requirements of EO 14411 apply to all IORs, and U.S. buyers must likewise maintain compliance records under subsequent rules.

VIII. Appendices

Appendix A: Glossary

Term	English	Definition
Importer of Record	Importer of Record (IOR)	The entity legally responsible for customs declaration, classification, valuation, origin, and duty payment
U.S. IOR	U.S. IOR	A U.S. citizen/green card individual as defined by this rule, or an entity meeting the three requirements of place of establishment, location, and 51% beneficial owner control (or real property)
Foreign IOR	Foreign IOR	An importer that does not meet the U.S. IOR standards
CTPAT	Customs Trade Partnership Against Terrorism	A voluntary CBP supply chain security partnership program; the importer category is open only to U.S. importers and Canadian non-resident importers
CVCB	CTPAT-Validated Customs Broker	A licensed customs broker that has obtained CTPAT validation; the statutory customs clearance channel for foreign IORs under this rule
CEE	Center of Excellence and Expertise	A nationwide trade processing center established by CBP by industry, responsible for verifying U.S. IOR eligibility
Interim final rule	Interim Final Rule (IFR)	A rule that takes effect while skipping prior comment and simultaneously solicits comments
Formal Entry / Informal Entry	Formal Entry / Informal Entry	Generally bounded at USD 2,500; informal entry procedures are simplified
Entry for Consumption	Entry for Consumption	The type of entry for goods entering U.S. domestic market circulation (Type 01, 11, etc.)
Immediate Delivery	Immediate Delivery (ID)	A procedure allowing goods to be released before the entry summary is submitted
live entry	Live Entry	An entry method under which all declarations and duty payments must be completed before release
Beneficial Owner	Beneficial Owner	The natural person who ultimately enjoys ownership interests or exercises control
Power of Attorney	Power of Attorney (POA)	A legal document by which the importer authorizes the customs broker to handle customs business, and it must be signed directly with the IOR
Continuous Bond / Single Transaction Bond	Continuous Bond / Single Transaction Bond	Annual bond and per-entry bond
Form 5106	CBP Form 5106	Importer identity registration form; starting 9-18, if the information is inaccurate, the IOR number can be directly voided

Appendix B: U.S. IOR eligibility self-assessment form

Fill in “Yes / No” for each item; if any required element is “No”, it is a foreign IOR.

#	Self-assessment item	Yes / No	Evidence
1	The entity is established under U.S. federal or state law (the Secretary of State registration document is valid and the entity is in good standing)		Certificate of registration, annual report
2	Principal place of business is in the United States (principal place of business)		Lease, utilities, employees
3	Substantial operating presence of the entity in the United States (not a registered agent address, not a virtual office)		Photos of office premises, business records
4	Has sufficient tangible assets in the United States		Asset list, financial statements
5a	At least 51% of beneficial owners are U.S. citizens or green card holders		Passport / green card, proof of shareholding
5b	The above-mentioned U.S. beneficial owners have actual control over the entity (board of directors, signing authority, control of funds)		Articles of incorporation, resolutions, bank authorization
5c	(Alternative path) Directly holds a considerable amount of unencumbered U.S. real estate		Title deed, proof of no encumbrance
6	The above status can be maintained “at all times” (no planned equity changes)		Shareholder commitment
Conclusion	□ U.S. IOR (1–4 are all “Yes”, and 5a+5b or 5c is “Yes”, and 6 is “Yes”) □ Foreign IOR (all other circumstances)		Responsible person signature / date

Appendix C: CVCB due diligence document checklist (foreign IOR)

Category	Materials	Consistency requirements
1. Legal identity	State registration certificate, articles of incorporation / operating agreement, EIN letter (CP 575 / 147C), Form 5106 receipt, business license (if any)	Name, address, and EIN must be fully consistent with 5106
2. Equity and beneficial owners	Equity structure chart (penetrating to natural persons), registration documents of shareholders at each tier, passports of beneficial owners, proof of shareholding, FinCEN BOI filing (if applicable)	Consistent with the optional fields of 5106
3. Control and affiliated enterprises	List of directors / senior officers, authorized signatories, list of affiliated companies and description of relationships, business license of the Chinese parent company	Signatories must complete identity verification
4. U.S. assets and ability to pay	Proof of U.S. bank account, recent bank statements, financial statements, guarantee information (guarantee company, guarantee number, limit)	Account name must be consistent with the IOR
5. Import and compliance history	Summary of customs declaration records for the past 3–5 years, ACE account information, CBP correspondence (CF-28/29), penalty or liquidation records	Disclose truthfully
6. Supply chain information	List and addresses of manufacturers / suppliers, freight forwarders and carriers, warehousing and distribution, product catalog	Consistent with ISF and invoices
7. Classification, valuation, and country of origin	Basis for HTS classification, transaction invoices and price composition, certificates of origin, relevant PGA (FDA, CPSC, etc.) compliance documents	Create a file for each SKU

Appendix D: Information sources and regulatory citations

This document is cited by textual annotation and contains no external links.

•U.S. Customs and Border Protection, Interim Final Rule, “Heightened Requirements for Foreign Importers of Record,” FR Doc. 2026-22735, filed for public inspection 2026-11-05, scheduled publication 2026-11-06, 81 pages.

•Executive Order 14411, “Strengthening Customs Enforcement,” 2026-06-03, 91 FR 35125 (FR Doc. 2026-11595).

•CBP, CTPAT Alert to Customs Brokers on due diligence for foreign importers of record, 2026-08-13.

•CBP, Notice, “Accuracy of Importer of Record Data Submitted to CBP,” 2026-08-19, 91 FR 53627 (FR Doc. 2026-16911).

•CBP, ANPRM, “Heightened Import Disclosures for Supply Chain Visibility,” 2026-09-02, Docket USCBP-2026-1058 (FR Doc. 2026-17926).

•CBP, NPRM, “Low-Value Shipments,” 2026-10-08, Docket USCBP-2026-0298 (FR Doc. 2026-20650).

•CBP, Final Rule, “Modernization of the Customs Broker Regulations,” 87 FR 63267 (2022), 19 CFR Part 111.

•CBP, NPRM, “Customs Broker Verification of an Importer’s Identity,” 84 FR 40302 (2019-08-14).

•19 U.S.C. 1484, 1498, 1592, 1641; 19 CFR 24.5, 111, 141.18, 143.

•Sandler, Travis & Rosenberg, P.A., STR Trade Report, “CBP Imposes Heightened Requirements for IORs and Customs Brokers,” 2026-11-05.

•Client briefings on EO 14411 by Holland & Knight, WilmerHale, RSM US, Worldwide Logistics Group, Flexport, and other institutions (June–October 2026).

Original verification checklist (V1.1 update items)

After the main text of the rule is published, it is recommended to prioritize verification of: the wording “located in the United States” and “significant amount of unencumbered real property” in the § definitions clause; the CEE verification standards; the list of records that customs brokers must review and the retention period; the applicability to in-bond / FTZ / bonded warehouse entry / Type 13; the continuous bond clause; and the number of affected foreign IORs and CVCBs estimated by CBP in the regulatory impact analysis. After verification, this document will be updated to V1.1.

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