At 00:01 U.S. Eastern Time on September 18, U.S. Customs and Border Protection (CBP) officially launched a penetrating verification mechanism for IOR (Importer of Record) information across all commercial import channels. All cargo exported to the United States—whether still at sea, already arrived at port, or currently being loaded—is included in the scope of verification. Simply put: from today on, U.S. Customs is not just inspecting goods; it is also inspecting "who is importing."
Key Numbers for the New IOR Rules
Effective date: September 18, 2026, 00:01 (U.S. Eastern Time)
Retroactive period: CBP can conduct retroactive audits for up to 5 years
Maximum penalty: 3 to 4 times the value of the goods
Affected freight forwarder models: double clearance with tax included, shared IOR, affiliated shell importers
Parties affected: Chinese sellers, U.S. freight forwarders, U.S. customs brokers
"Checking the Person" Rather Than "Checking the Goods": What Exactly Has Changed?
For more than a decade, there has been a commonly used "convenient solution" in foreign trade circles: if you do not have your own U.S. company, you find a freight forwarder or customs broker to affiliate with, use their IOR for customs clearance, and pay a freight rate that includes tax, commonly known as "double clearance with tax included" or "DDP." On CBP Form 5106, the company name, address, tax ID, email, and phone number all belong to someone else—everyone knew this, but no one was regulating it.
Starting today, things are different. In Federal Register Notice 91 FR 53627, CBP made it clear: IOR registration information must be 100% attributable to the importer itself, including a real business address (registered agent addresses or virtual offices are not allowed), an owned phone number and email (freight forwarder numbers cannot be used to receive notices), an EIN (borrowing or affiliation is strictly prohibited), and a POA (power of attorney) that must be signed directly with the customs broker and may not be transferred through a third party.
The consequences of violation in one sentence: the IOR number is immediately invalidated, cannot be used for any import declaration, and in-transit goods are directly frozen. There is no rectification buffer period and no prior warning. Once the goods arrive at port, they are detained, and subsequent demurrage, container rent, and storage fees are fully borne by the cargo owner. In serious cases, the goods may be returned or confiscated.
In-Transit Cargo Is Most at Risk: These Containers May Be Detained Upon Arrival
Many foreign trade professionals cling to wishful thinking: "The goods are already at sea, so they can't be pulled back, right?"
Wrong. After the new rules take effect, as long as the IOR information of in-transit cargo at sea is judged abnormal, it will still be stuck at the port and unable to enter. CBP's ACE system began pre-flagging high-risk IORs such as affiliated addresses, borrowed EINs, and virtual email boxes at the end of August. Many containers that cleared customs normally in August are now being re-scored. Industry estimates suggest that for a 40HQ container worth $80,000 arriving at LAX, seven days of port detention generates about $1,050 to $2,100 in container rent and storage fees (approximately RMB 7,500 to 15,000), not including losses from missing Amazon Prime Week or shrinking platform inventory windows.
Scenario | Risk Under New Rules | Recommended Action |
In-transit cargo + affiliated IOR | High risk | Immediately contact customs broker to verify IOR status |
Freight forwarder shared IOR + tax-inclusive quote | High risk | Request replacement with a real IOR or establish your own entity |
Virtual address + shared phone/email | Medium risk | Update to a real business address |
Own U.S. entity + directly signed POA | Compliant | Verify information accuracy and keep it updated |
Foreign IORs Are a Key Target
The definition of "foreign importer" in the new rules is especially noteworthy: any Chinese company that does not meet the U.S. IOR definition is classified as a Foreign IOR—meaning the vast majority of cross-border sellers clearing customs directly as Chinese companies are within the highest priority scope of this verification.
More critically, even if customs clearance is conducted in the name of a U.S. LLC, as long as the ultimate beneficial owner is a Chinese citizen, it may still be deemed a Foreign IOR, subsequently facing additional restrictions such as informal entry bans and limited continuous bonds. The common belief that "registering a U.S. company makes you a U.S. importer" is being completely overturned by CBP's penetrating review.
Six Types of Addresses Are Explicitly Prohibited
CBP has made it clear that the following six types of addresses cannot be used as the IOR's actual business address:
① Registered agent address; ② Customs broker address; ③ Freight forwarder address; ④ P.O. box; ⑤ Business service center address (including virtual offices and CMRA-type addresses); ⑥ Any other third-party or affiliated address.
Consequences Go Beyond Invalidation
In addition to immediate invalidation of the IOR number and detention of goods upon arrival, companies that intentionally submit false information will also face fines and even criminal liability. Customs brokers who continue to declare while knowing the information is false will also be held accountable, and in serious cases their customs broker qualifications may be revoked.
What Can Still Be Done Now?
If you are a seller doing business in the U.S. market, it is recommended to do three things immediately:
First, self-check IOR registration information. Log in to CBP's ACE Secure Data Portal and verify whether the actual address, mailing address, phone number, and email associated with each IOR are genuine and belong to you. If you have not yet opened an ACE account, register immediately.
Second, contact your freight forwarder or customs broker to confirm compliance status. If you are using a freight forwarder's IOR for customs clearance, immediately ask them to provide proof of IOR qualifications. If they are vague or unable to confirm, the risk level of this shipment needs to be reassessed.
Third, assess the necessity of establishing your own U.S. entity. For sellers doing long-term business in the U.S. market, registering a U.S. company, applying for an EIN, and applying for IOR qualifications yourself are shifting from "optional" to "essential." In the short term, the cost is higher, but compared with the price of goods being detained and accounts being closed, this investment is worthwhile.
To verify U.S. importer qualifications and view real buyer lists, you can use the Big Trade Data customs data platform to filter real purchasing records of U.S. importers by HS code and destination country, helping to judge the compliance level of partners.
The era of grey customs clearance is closing, and the threshold for compliant customs clearance is rising. For foreign trade professionals who are serious about the U.S. market, this may not be a bad thing—the clearer the rules, the more advantage real players have.