CBP’s new interim final rule on importer of record (IOR) requirements represents a significant change for both U.S. and non-resident importers, as well as the customs brokers that serve them. While designed to provide new requirements for foreign IORs, the rule also creates significant new qualification and verification standards for U.S. importers, imposes increased due diligence and recordkeeping responsibilities on customs brokers, establishes CTPAT-related requirements for non-resident IORs, and potentially increases brokers’ exposure to penalties under 19 U.S.C. § 1592. Meanwhile, CBP is actively voiding importers of record for inaccurate data on the 5106 Importer Identity Form.
This webinar will break down what importers and brokers need to know, including who qualifies as a U.S. IOR, the documentation brokers will be expected to review and retain, how the new rules affect non-resident importers, and what CBP’s heightened enforcement framework could mean in practice. We’ll also discuss the implementation timeline, opportunities to comment, and the option for brokers to request additional time to comply.
