Act nowHomeland Security Department, U.S. Customs and Border Protection · Tariffs & customsDeadline Jan 5, in 54 days7/7 quoted sentences found in the source

From January 5, a foreign importer of record can enter goods only if it is CTPAT validated or uses a CTPAT-validated broker

CBP published an interim final rule that splits importers of record into U.S. and foreign. A company counts as a U.S. importer only if it is organized and located in the United States and is either at least 51% owned and controlled by U.S. citizens or permanent residents, or directly owns a significant amount of U.S. real property. Everyone else is a foreign importer of record and, from January 5, 2027, can make entry only if it is CTPAT validated or files through a CTPAT-validated customs broker. Comments are open until the same day.

EffectiveJanuary 5, 2027
U.S. ownership testat least 51%
Brokers fully compliant byMay 6, 2027

What the document says

Matched to source. The rule takes effect January 5, 2027.
Matched to source. A U.S. importer of record must be U.S.-organized, U.S.-located, and either 51% U.S.-owned and controlled or an owner of significant U.S. real property.
Matched to source. Any importer that does not meet that test is a foreign importer of record.
Matched to source. A foreign importer must be CTPAT validated or use a CTPAT-validated broker to make formal entry.
Matched to source. CBP's stated reason is unpaid duty: it collected 3.1% of what audits found foreign importers owed.
Matched to source. Brokers can ask for more time, but all must comply by May 6, 2027.
Matched to source. Comments close January 5, 2027.

Who does this affect?: Canadian, UK, EU, and Chinese brands that import into the United States in their own name as non-resident importers; U.S.-registered companies whose owners are not U.S. citizens or permanent residents; and the customs brokers and 3PLs that file for them.
What it costs: CBP states no fee. Its stated reason is $1.16 billion in lost revenue found in audits of foreign importers of record, of which it recouped $35.7 million (3.1%); from January 5, 2027 an entry by a foreign importer that meets neither condition is not allowed.
What to check: If the company named as importer on your entries is foreign-owned or based outside the United States, ask your customs broker two things this month: whether CBP will treat you as a foreign importer of record under the new ownership and real-property test, and whether the broker itself is CTPAT validated. The rule and its comment docket (USCBP-2026-1387) are where to read the test in full.

The headline, summary, who, cost, and what-to-check lines are our reading of the document, not the document’s words and not advice.

Primary source

Heightened Requirements for Foreign Importers of Record