What exactly changed with the new CBP interim final rule on January 5?

The CBP introduced new requirements for foreign importers of record (IORs) making formal and informal entries into the US. A foreign IOR with CTPAT validation can now make entries independently or appoint a licensed customs broker that does not require CTPAT validation. However, a foreign IOR without CTPAT must designate a broker that is both licensed AND CTPAT-validated. Additionally, stricter criteria now apply for determining US IOR eligibility, including requirements that individuals be US citizens or lawful permanent residents, and companies must be organized under US law with at least 51% beneficial ownership by US citizens or permanent residents.

How does this affect DDP (Delivered Duty Paid) arrangements between overseas suppliers and US buyers?

Under traditional DDP terms, the overseas supplier typically arranges import clearance and pays duties and taxes, offering US buyers a simplified import process. The new rules make this arrangement harder to execute because both parties must now verify that whoever is named as the importer of record meets stricter CBP eligibility criteria. US buyers can no longer treat a DDP quotation alone as a guarantee of compliance, and must now explicitly confirm who is named as the IOR, which customs broker is filing the entry, and whether those parties satisfy CBP conditions.

What documentation and verification are customs brokers now required to maintain?

Licensed customs brokers must verify a client's eligibility before declaring them a US IOR. They must request and review supporting records, which could include corporate documents, financial statements, and proof of citizenship or permanent residence. All verification records must then be retained for five years. Brokers had until May 6 for full compliance, though they could request delayed compliance before January 5.

Why is CBP implementing these stricter requirements now?

CBP stated that these measures are intended to improve visibility of foreign importers, strengthen accountability, and help ensure duties are collected. The agency highlighted difficulties in pursuing unpaid duties and enforcing customs requirements against foreign entities with few US assets. This reflects what industry observers are calling 'the age of strengthening customs enforcement.'

What should US importers do to prepare for these new rules?

US buyers should establish exactly who is responsible for the import process when overseas suppliers sell on DDP terms. They must ask their suppliers who is the importer of record, which customs broker is being used, what the arrangement looks like, and whether it meets the new CBP requirements. This due diligence should occur before placing orders to avoid compliance violations and potential shipment delays.

Trade Policy & Tariffs

High Impact

CBP Tightens DDP Import Rules: New Compliance Burden for US Buyers

Nov 9, 2026

Get tomorrow's supply chain signal

Daily supply-chain brief. Free, unsubscribe anytime.

The signal

The US Customs and Border Protection agency has issued new interim final rules that significantly tighten requirements for foreign importers of record (IORs) and licensed customs brokers handling Delivered Duty Paid (DDP) transactions. The rules take effect January 5 and require stricter CTPAT validation, enhanced verification of US IOR eligibility (with proof of citizenship, company incorporation in the US, and 51% US beneficial ownership), and mandatory five-year record retention by brokers.

This represents a structural shift away from the "easy button" convenience that overseas suppliers offered under traditional DDP arrangements. Supply chain professionals must now conduct thorough due diligence on DDP quotations to ensure the underlying import arrangements comply with CBP conditions, adding operational complexity and potential delays to import processes.

How this affects:

Global Fuel Surcharges Air and Ocean Freight

Open the full daily intelligence brief · Pulse 73

Frequently Asked Questions

What This Means for Your Supply Chain

Simulation Suggestion

this week

What if your US IOR does not meet the new beneficial ownership requirements?

Simulate scenarios where your designated US IOR (whether your company or a third party) fails to meet the new 51% US beneficial ownership and citizenship criteria. Model the operational impact of shipment holds, re-designation of IOR, compliance delays, and potential duties owed. Calculate the cost of restructuring your IOR arrangement or appointing a compliant alternative entity. Assess timeline impacts to your import schedule and whether expedited customs clearance options exist.

Run this scenario

Simulation Suggestion

immediate

What if your DDP supplier does not have CTPAT validation?

Simulate the operational impact if your foreign DDP supplier lacks CTPAT validation and therefore must now designate a licensed CTPAT-validated customs broker to act as IOR. Model increased lead times due to broker coordination delays, additional documentation requirements, and potential rejection of entries if broker credentials are not properly verified. Assess cost increases from additional broker fees and compliance documentation. Compare against alternative sourcing arrangements or switching to different Incoterms.

Run this scenario

Simulation Suggestion

strategic

What if compliance verification delays push your shipment past peak season window?

Model the financial and operational impact if customs broker verification procedures cause your DDP shipment to be delayed beyond a critical peak season or promotional window. Quantify lost sales, markdowns on delayed inventory, and potential supply chain cascades (stockouts, expedited alternative sourcing, safety stock buildup). Assess whether expedited broker verification or pre-clearance certification could mitigate delays. Calculate the cost of these mitigation strategies against the revenue impact of missing the window.

Run this scenario

Go deeper:

Digital Twin in Supply Chain: What It Is and How to Choose Software

What a supply chain digital twin is, how to evaluate twin software, what it costs and how long it takes, and how it differs from network design tools.

Trade Policy & TariffsHigh Impact

CBP Now Voids IOR Numbers for Form 5106 Errors: What You Need to Know

Sep 30, 2026

Trade Policy & TariffsHigh Impact

CBP Tightens Low-Value Import Rules: Early Filing Now Required

Oct 20, 2026

Trade Policy & TariffsHigh Impact

CBP Forced Labor Rules Mandate Full Supply Chain Visibility

Jul 1, 2026

Get the daily supply chain briefing

Top stories, Pulse score, and disruption alerts. No spam. Unsubscribe anytime.