Customs and Border Patrol (CBP) Publishes Interim Final Rule Heightening Requirements for Foreign Importers of Record

On November 6, 2026, U.S. Customs and Border Protection (CBP) published an interim final rule, effective January 5, 2027, strengthening requirements for foreign Importers of Record (IORs). The rule distinguishes between U.S. and foreign Importers of Record, with U.S. Importers of Record defined as U.S. citizens, lawful permanent residents, or qualifying U.S.-organized entities that meet specific ownership and control requirements. Any Importer of Record that does not meet these criteria is considered a foreign Importer of Record.

Foreign Importers of Record must be validated under the Customs-Trade Partnership Against Terrorism (CTPAT) program or designate a Customs-Trade Partnership Against Terrorism-validated, licensed customs broker to handle entry or serve as the Importer of Record. If the foreign Importer of Record does not own or purchase the merchandise, the broker must serve as the Importer of Record. This could significantly limit foreign importing, as only 0.4% of foreign IORs are currently Customs-Trade Partnership Against Terrorism-validated.

U.S. Importers of Record may continue importing without Customs-Trade Partnership Against Terrorism validation but must submit a declaration confirming their eligibility. All importers must declare whether they qualify as a U.S. or foreign Importer of Record on every entry and entry summary. Customs brokers may submit the declaration on behalf of their clients but must verify that they meet the U.S. Importer of Record requirements.

To view the Federal Register notice, click here. 

The RV Industry Association will continue to provide information as it becomes available. For a comprehensive overview of tariffs currently enacted, view the tariff tracker. 

Please contact Samantha Rocci, Director of Federal Affairs (srocci@riva.org), with questions or for more information.