As a follow-up to our recent advisory, "CBP Issues New Requirements for Foreign Importers of Record," U.S. Customs and Border Protection (CBP) has released several additional resources to help importers understand and comply with the new U.S. Importer of Record requirements effective as of January 5th, 2027.
These materials provide further guidance on the Interim Final Rule and address many of the questions CBP has received from the trade community regarding eligibility, documentation requirements, verification procedures, and compliance expectations.
CBP hosted a webinar on November 6, 2026, to explain the new requirements and answer stakeholder questions. Importers and foreign entities considering serving as the Importer of Record are encouraged to review the presentation.
Webinar: Heightened Requirements for Foreign Importers of Record
CBP has created a dedicated webpage consolidating information regarding its customs enforcement initiatives, including enhanced oversight of foreign importers of record including Frequently Asked Questions (FAQs).
Resource: Strengthening Customs Enforcement
This guide provides practical information regarding the rule's requirements, compliance obligations, and implementation details.
Resource: Foreign Importer of Record Interim Final Rule Reference Guide
CBP's overview document summarizes the purpose of the rule, affected parties, and key regulatory changes.
Resource: Foreign Importer of Record Interim Final Rule Overview
All importers of record and companies utilizing foreign entities as the importer of record should review these resources carefully to understand CBP's heightened verification requirements and ensure all required documentation, tax registrations, and business records are current and readily available.
Organizations that may be affected by the new requirements should also evaluate their importer of record structures and compliance processes ahead of the rule's implementation and any future CBP verification requests.
C.H. Robinson will continue to monitor CBP's implementation of these enhanced requirements and provide updates as additional guidance becomes available.
Please reach out to your C.H. Robinson representative with any questions.
Related Advisory: CBP Issues New Requirements for Foreign Importers of Record