Foreign importers of record need CTPAT validation or a CTPAT broker from January 5, 2027
CBP title: Updates to CBP Form 3461 and CBP Form 7501, and their Electronic Equivalents, Pursuant to the Interim Final Rule on Heightened Requirements for Foreign Importers of Record
Action required by January 5, 2027
This message asks importers or filers to act. The position below says what to do.
What did CBP announce?
CBP announced an interim final rule with new requirements for foreign importers of record (IORs). From January 5, 2027, a foreign IOR must be CTPAT validated or designate a CTPAT validated broker to enter goods for consumption. CBP added three new data fields to CBP Form 3461 and CBP Form 7501 and their electronic equivalents. CBP may reject entries and entry summaries that do not meet the new checks from January 5, 2027.
What is Allied's position?
The new data fields apply to the entries and entry summaries we file, including a Y or N flag on whether the IOR meets the U.S. IOR criteria. Foreign IOR clients should contact us well before January 5, 2027 to confirm how their entries will be filed under the new rule. Please make sure your CBP Form 5106 and power of attorney details are current. Ask us to review your entries if you are unsure whether you meet the U.S. IOR criteria.
General information, not legal advice.
What does the CBP message say?
Pursuant to Executive Order 14411, “Strengthening Customs Enforcement”, Section 2, and governing statutes, U.S. Customs and Border Protection (CBP) is establishing new requirements for foreign importers of record (IORs) when making entry, and corresponding responsibilities for licensed customs brokers. See Interim Final Rule (IFR), “Heightened Requirements for Foreign Importers of Record”, 91 FR 69977, dated November 6th, 2026.
This message is to inform the trade of new data fields for the CBP Form 3461 and CBP Form 7501, and their electronic equivalents.
As of January 5th, 2027, the IFR requires that, in order to enter or withdraw goods for consumption, a foreign IOR must be Customs Trade Partnership Against Terrorism (CTPAT) validated or designate a CTPAT validated broker to make entry.
Three new data fields have been added to CBP Form 3461 and CBP Form 7501 and their electronic equivalents:
1. “U.S. Importer of Record” Select “Y” when:
- the IOR meets the U.S. IOR criteria; or
- a broker acts as IOR and the principal on the power of attorney (principal) meets the U.S. IOR criteria.
Select “N” when the IOR or applicable principal does not meet those criteria.
2. “Acting on behalf of” - If the broker lists themselves as the filer and IOR: Select “Y” when the customs broker lists itself as both the filer and IOR for purposes of filing entry on behalf of the principal; otherwise select “N”.
3. “Principal on Power of Attorney” Required when a non-CTPAT validated broker acts as the IOR on behalf of a principal. The broker must report the principal’s IOR number, such as SSN, EIN, or CBP-Assigned number, linked to the principal’s CBP Form 5106.
CBP has built additional validation checks and may reject entries and entry summaries as of January 5th, 2027, if:
- A foreign IOR attempts to file entry without being CTPAT validated or without a CTPAT validated customs broker; or
- The non-CTPAT validated customs broker, when acting as the IOR, does not provide the principal when required.
As needed, brokers may submit a delayed compliance request no later than January 5th, 2027, see http://www.cbp.gov/trade/strengthening-customs-enforcement/delayed-compliance.
With publication of the IFR, a pre-recorded webinar providing an overview of the new requirements pursuant to this IFR will be posted on https://www.cbp.gov/trade/strengthening-customs-enforcement.
Questions regarding this message may be sent to the Office of Trade, Trade Modernization Division, at ForeignIOR@cbp.dhs.gov. (mailto:ForeignIOR@cbp.dhs.gov)
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