New US Importer of Record (IOR) Rules for 2027: What Amazon Sellers and Importers Need to Know

U.S. Customs and Border Protection (CBP) is tightening Importer of Record (IOR) requirements through a series of enforcement measures and new regulations. The first major change began on September 18, 2026, when CBP started reviewing the accuracy of importer information submitted through CBP Form 5106. On November 6, 2026, CBP published an interim final rule introducing additional requirements for foreign importers of record. The new rule takes effect on January 5, 2027. For Amazon FBA sellers, e-commerce businesses, and companies shipping goods from China to the United States, verifying IOR status, ownership structure, customs broker arrangements, and filing responsibilities should be an immediate priority.

US IOR Rule Changes: Key Dates Importers Should Know

The latest changes follow Executive Order 14411, "Strengthening Customs Enforcement," signed on June 3, 2026. The order directs the Department of Homeland Security (DHS) and CBP to strengthen importer identification, financial accountability, and enforcement of U.S. customs laws.

There are three important dates in the implementation process:

Important clarification: November 30, 2026, was associated with the 180-day implementation timeline established by the June executive order. It is not the effective date of the newly published foreign IOR rule. The actual effective date specified in CBP's November 6 interim final rule is January 5, 2027.

CBP Form 5106: Six IOR Information Fields Under Review

CBP Form 5106, also known as the Create/Update Importer Identity Form, is used to establish or update an importer's identity information with U.S. Customs.

According to CBP's August 19, 2026 Federal Register notice, the form requires six core information categories:

• · Importer Name: The correct legal name of the individual or business acting as the IOR.
• · Tax Identification Number: The applicable EIN, SSN, or CBP-assigned number.
• · Mailing Address: The importer's designated correspondence address.
• · Physical Location Address: The actual business or individual location, if different from the mailing address.
• · Phone Number: A valid number belonging to the IOR.
• · Email Address: A valid email address belonging to the IOR.

CBP requires this information to be accurate, complete, and directly associated with the importer. If CBP determines that the submitted information is inaccurate or incomplete, it may immediately void the associated IOR number.

Three Documentation Issues Importers Must Address

1. Physical business address

The physical address must represent the actual location of the business or individual. CBP specifically states that a registered agent's address, customs broker's address, freight forwarder's address, P.O. box, business service center, or another party's address cannot be substituted for the IOR's physical address. A business principal's home address may qualify where applicable.

2. Email and telephone ownership

The email address and phone number submitted on Form 5106 must belong to the IOR. A customs broker or freight forwarder cannot simply replace the importer's contact details with its own information.

3. Direct Power of Attorney (POA)

When a licensed customs broker submits Form 5106 on behalf of an importer, the broker must hold a valid POA executed directly with that IOR. The authorization cannot be routed through a freight forwarder or another third party as a substitute for the required direct relationship.

If CBP voids an IOR number, it will issue written notice to the most recently submitted email address. The notice will explain the basis for the action and provide information about requesting reestablishment. Importers should therefore maintain access to their registered email accounts and ensure that contact details remain current.

(Source: CBP, 08/2026 – Accuracy of Importer of Record Data Submitted to CBP, 91 FR 53627)

Does Registering a US Company Automatically Make You a US IOR?

No. This is one of the most important distinctions introduced by the November 2026 rule.

Registering an LLC or corporation in the United States does not automatically qualify that entity as a U.S. Importer of Record. Under the new 19 CFR Part 110, CBP establishes specific criteria for distinguishing U.S. IORs from foreign IORs.

Who Qualifies as a US Importer of Record?

Under the new rule, an individual must be a U.S. citizen or lawful permanent resident to qualify as a U.S. IOR.

For a business entity, the requirements include:

• · The entity must be located in the United States.
• · The entity must be organized under U.S. law.
• · It must satisfy one of the following ownership or property requirements:
• · At least 51% of its beneficial owners must be U.S. citizens or lawful permanent residents who control the entity; or
• · The entity must directly own a significant amount of unencumbered real property in the United States at all times.

CBP also reserves the right to verify whether an entity genuinely operates as a U.S.-located business. Factors may include its principal place of business, physical operations, employees, revenue-generating activities, domestic assets, profitability, and capitalization.

How Does This Affect Chinese-Owned US Companies?

Consider a Chinese e-commerce seller that establishes a U.S. LLC. The company is legally registered in the United States, but its beneficial ownership and control remain entirely with Chinese individuals.

Under the new criteria, the company would not automatically qualify as a U.S. IOR simply because it holds a U.S. registration certificate. If it does not satisfy the U.S. beneficial ownership requirement or the alternative real-property ownership requirement, it will generally be classified as a foreign IOR.

However, foreign ownership alone does not automatically disqualify every U.S.-organized entity from U.S. IOR status. The alternative qualifying real-property provision must also be considered, and CBP makes the final determination based on the applicable criteria and verification.

The key takeaway: Company registration, EIN ownership, and U.S. IOR qualification are three different matters. Importers must evaluate their actual ownership, control, operations, and qualifying assets rather than relying solely on the state registration of their company.

New Requirements for Foreign Importers: CTPAT and Customs Brokers

The November 6 interim final rule introduces a significant change for foreign IORs. Starting January 5, 2027, foreign importers must satisfy additional requirements when entering merchandise for consumption into the United States.

Under the new rule, there are two main compliance pathways:

Option 1: The Foreign IOR Is CTPAT Validated

A foreign IOR that has been validated through the Customs Trade Partnership Against Terrorism (CTPAT) program may make eligible entries directly or appoint a licensed customs broker to handle the filing.

The importer must still satisfy applicable entry requirements and maintain its regulatory responsibilities.

Option 2: Use a CTPAT-Validated Licensed Customs Broker

A foreign IOR that is not CTPAT validated must designate a licensed customs broker that is CTPAT validated to make the entry or act as the IOR where permitted under the applicable rule.

This is an important change because simply hiring any licensed customs broker will no longer be sufficient for a non-CTPAT foreign IOR under the new requirements.

There is also an important distinction between using a CTPAT-validated broker and becoming a CTPAT participant yourself. Hiring a validated broker does not automatically transfer CTPAT status or benefits to the foreign importer.

Will Foreign IORs Still Be Allowed to Use Informal Entry?

The executive order directed DHS to prohibit foreign IORs from using informal entry. However, CBP's November 6 interim final rule did not implement a complete prohibition at this stage.

Instead, the rule permits foreign IORs to make eligible informal entries when the applicable CTPAT requirements are met. CBP will continue monitoring these transactions and may introduce further restrictions if it determines that additional measures are necessary to protect customs revenue, national security, or public health.

For e-commerce sellers and businesses handling lower-value shipments, this distinction matters. It would be inaccurate to claim that all foreign IORs are already prohibited from informal entry under the current interim final rule.

What About Customs Bonds and Financial Requirements?

Executive Order 14411 directs DHS and CBP to strengthen financial accountability by requiring minimum levels of domestic assets, bonding, or both, and by increasing minimum bond coverage.

The new rule also defines physical domestic assets to include:

• · Cash deposited in a U.S. bank account.
• · U.S. Treasury bonds.
• · Real property located in the United States.
• · Inventory physically located in the United States.
• · Machinery and equipment physically located in the United States.

CBP specifically excludes certain intangible assets, such as accounts receivable, from this definition.

Importers should not assume that every financial requirement mentioned in the executive order has already been implemented through the November 6 interim final rule. Nor should they assume that all foreign IORs are automatically prohibited from using continuous bonds under this rule. Bond coverage and related requirements must be evaluated against the applicable CBP regulations and subsequent official updates.

IOR Compliance Checklist for Amazon FBA and US Importers

Amazon's U.S. seller guidance makes clear that Amazon and its fulfillment centers will not act as the IOR for sellers' imported inventory. The seller or its designated importer remains responsible for customs compliance, entry documentation, and applicable duties and taxes.

Before arranging your next shipment, review the following areas:

• · IOR identity: Confirm that the legal entity named in the customs entry is the correct importer.
• · Form 5106: Review the importer name, tax identification number, mailing address, physical address, phone number, and email address.
• · Ownership structure: Determine whether the entity qualifies as a U.S. IOR or a foreign IOR under the new criteria.
• · POA authorization: Confirm that the customs broker has a valid POA executed directly with the IOR.
• · CTPAT arrangements: If the importer is foreign, confirm whether it needs its own CTPAT validation or a CTPAT-validated licensed customs broker.
• · Bond arrangements: Review existing bond coverage and confirm whether additional requirements apply to the shipment and importer.
• · Entry procedures: Confirm that the customs broker is prepared to meet the January 5, 2027 requirements.

Do not wait until a shipment reaches a U.S. port to discover that the IOR information or broker arrangements are not compliant.

How ANL Supports China-to-US Import Logistics

IOR eligibility and customs entry decisions are determined under U.S. law and remain the responsibility of the importer, CBP, and appropriately authorized customs professionals. A freight forwarder cannot independently grant U.S. IOR status or guarantee customs release.

However, coordinating transportation, documentation, customs clearance, and cargo handling can help importers manage the operational impact of regulatory changes.

American New Logistics (ANL), established in 2008, provides China-to-US ocean freight, air freight, customs clearance coordination, transloading, U.S. warehousing, and drayage and delivery services.

With more than 400,000 square feet of U.S. warehouse capacity across major logistics gateways and a local fleet of more than 60 trucks, ANL supports importers with transportation planning and cargo handling after the relevant customs and regulatory requirements have been satisfied.

Companies planning shipments to the United States can explore ANL's ocean freight services, customs clearance services, and transloading solutions.

Conclusion

The new U.S. IOR requirements represent a significant shift in how CBP identifies importers, verifies business ownership, and oversees foreign companies importing merchandise into the United States.

For cross-border sellers, the biggest mistake would be assuming that an existing EIN, a registered U.S. LLC, or a long-standing customs broker relationship automatically guarantees compliance.

Review your Form 5106 information, verify your actual IOR classification, confirm your customs broker's CTPAT status where required, and assess your bond arrangements before the January 5, 2027 implementation date.

For businesses shipping from China to the United States, regulatory compliance and logistics planning should be managed together. Getting the importer structure right before cargo departure can help reduce avoidable clearance delays and disruption to downstream distribution.

Frequently Asked Questions About the New US IOR Rules

1. When do the new US foreign IOR requirements take effect?

The CBP interim final rule was published on November 6, 2026, and takes effect on January 5, 2027. Customs brokers must fully comply with the new client verification requirements no later than May 6, 2027.

2. Can a Chinese-owned US LLC qualify as a US IOR?

Not automatically. It must meet the U.S. location and formation requirements, plus either the 51% qualifying beneficial ownership and control test or the alternative significant unencumbered U.S. real-property ownership test.

3. Can a foreign IOR use a regular licensed customs broker after January 5, 2027?

A non-CTPAT foreign IOR must designate a CTPAT-validated licensed customs broker to make entry or act as the IOR where permitted. A regular broker license alone is insufficient.

Official References

• · Executive Order 14411 – Strengthening Customs Enforcement (June 10, 2026)
• · CBP – Accuracy of Importer of Record Data Submitted to CBP (August 19, 2026)
• · CBP – Heightened Requirements for Foreign Importers of Record (November 6, 2026)
• · CBP CSMS #70381183 – Updates to CBP Forms 3461 and 7501 (November 6, 2026)
• · Amazon Seller Central – Delivering Imports to Amazon

Information compiled and reviewed by ANL's US Logistics Operations Team. Data and regulations are subject to official updates.