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Key Takeaways

• Customs: CBP’s foreign importer of record rule takes effect January 5, 2027. Confirm who will appear as the importer and which broker will file the entry.
• Section 301: USTR extended 178 product exclusions and separately extended a pause on specified maritime measures. Both run to January 9, 2027, with distinct eligibility and timing rules.
• Ocean: Drewry’s November 5 assessment showed Shanghai–New York down 3% and Shanghai–Los Angeles unchanged. Compare written quotes to the same delivery point.
• Air: FedEx added capacity across its Asia-Pacific–U.S. network. UPS’s November 2 schedule lists capacity surcharges for selected air freight services.
• Amazon: U.S. FBA fulfillment fees will rise by an average of $0.19 per unit sold. Most changes take effect January 15, 2027. Check the impact SKU by SKU.

CBP’s Foreign Importer of Record Rule Takes Effect January 5

U.S. Customs and Border Protection published an interim final rule on November 6 covering foreign importers of record, or IORs, and the brokers that serve them. It takes effect January 5, 2027, which is also the comment deadline. The rule covers formal consumption entries and specified informal entries filed using CBP Forms 3461 or 7501 or their electronic equivalents.

A foreign IOR validated under the Customs Trade Partnership Against Terrorism program, or CTPAT, may file if it has the right to make entry, or use a licensed customs broker. A foreign IOR without that validation must designate a licensed, CTPAT-validated broker to make entry or serve as IOR, as applicable. Under the rule, the validated broker must act as IOR when the principal on the power of attorney is neither the owner nor the purchaser of the merchandise.

For a Delivered Duty Paid (DDP) shipment, ask for the IOR’s legal name and the broker’s role in writing. If the arrangement relies on a U.S. affiliate, ask the broker to assess it against CBP’s U.S. IOR criteria. Confirm how the broker plans to complete the revised entry and entry summary fields, including the principal’s identifier where required.

Eligible brokers may request delayed compliance with specified broker requirements. CBP expects all brokers to be in full compliance by May 6, 2027. If a provider cites that date, ask whether it has an approved delay, which requirements it covers and how the broker will handle your entries. Before booking, gather the invoice, product specifications and importer details for a customs clearance document review.

Section 301 Tariff Exclusions: Check the Product and Entry Date

USTR announced on November 6 that it would extend all 178 current product exclusions. Annexes A and B cover HTSUS headings 9903.88.69 and 9903.88.70. The extension applies to qualifying goods entered for consumption or withdrawn from warehouse for consumption from 12:01 a.m. Eastern Time on November 10, 2026, and before 11:59 p.m. Eastern Time on January 9, 2027.

Have your broker match the product’s ten-digit HTSUS number and actual specifications to the exclusion description. For goods on the water, confirm the expected consumption-entry date. For goods in a bonded warehouse, confirm the planned withdrawal date for consumption. A December sailing can still fall outside the window if the relevant customs event occurs after the deadline.

If a purchase order could cross that deadline, model landed cost with and without the exclusion. Keep the specifications that support the product match and ask your broker to confirm the filing treatment. USTR said CBP would issue implementation instructions.

Section 301 Maritime Fee Suspension: Review the Freight Quote

USTR’s November 6 notice confirmed a further suspension effective November 9, 2026, through 11:59 p.m. Eastern Time on January 9, 2027. It covers specified maritime transport fees and duties on certain cargo-handling equipment under the maritime investigation. Product eligibility for the tariff exclusions above is determined under the separate product notice.

If a quote includes a maritime policy surcharge or contingency, ask the provider to identify the charge, its trigger and the dates covered by the quote. For cargo moving near the January deadline, get the assumptions in writing so your procurement team can reconcile any revised quote or invoice.

Transpacific Spot Rates: New York Fell While Los Angeles Held Steady

Drewry’s November 5 assessment showed different moves from the same origin.

Use the benchmarks to decide which lane to reprice. To compare bookable quotes, give both providers the same cargo-ready date, container size, final delivery ZIP code and receiving deadline. Ask what the quote includes after discharge, including inland transport and any delivery appointment requirements. For an inland destination, a lower ocean rate can lose its advantage if the onward connection costs more or misses the receiving window.

Air Freight: Check Available Space and the Capacity Surcharge

FedEx announced on November 3 that it added 567,000 kilograms of weekly capacity across its Asia-Pacific–U.S. network, including routes through Guangzhou and Shanghai. The figure covers multiple origins and connections. For your shipment, confirm the actual departure, cargo tender deadline and U.S. delivery point.

Separately, UPS’s November 2 schedule lists an air freight capacity surcharge of $2.01 per chargeable kilogram from listed North and East China origins to the U.S. and $1.57 from listed South China origins for covered services. At 100 chargeable kilograms, the capacity surcharge alone would be $201 or $157. Ask the provider to confirm the applicable service and origin, show the chargeable weight and state how capacity, fuel and other fees are treated in the quote.

If you are considering Amazon FBA air freight, start with the units needed to cover the stock gap. Allow time for delivery and receiving before those units can become available for sale. Price that quantity by air and the balance by ocean, then compare the combined cost with shipping the full order by air.

Amazon’s 2027 U.S. FBA Fees: Recalculate Margin by SKU

Amazon announced its 2027 U.S. fee updates on November 5. FBA fulfillment fees will rise by an average of $0.19 per unit sold, with most changes taking effect January 15, 2027. Fees will rise for some products and fall for others, depending on the product, size and price. Amazon also announced separate storage fee changes effective February 1, 2027, so use the effective date for each fee when updating your forecasts.

Start with high-volume SKUs and products with thin margins. In Seller Central, use Amazon’s Fee Change Comparison dashboard or Revenue Calculator to estimate the fee for each product. Keep Amazon fulfillment fees, FBA inbound costs such as placement fees where applicable, and China-to-U.S. freight and import costs on separate lines. When an inbound charge is already included in a door-to-door quote, account for it once.

For January replenishment, run the new fee estimate against the price and volume you expect to sell. Then compare the freight cost of your standard shipment with the cost of a smaller, faster replenishment. This shows whether the change in margin comes from Amazon’s fee schedule, the shipping plan or both.

What to Check Before Your Next Booking

• Customs: Record the IOR’s legal name, the broker’s role and the expected entry date. For any claimed exclusion, confirm the product match and applicable entry or withdrawal date.
• Ocean: Compare quotes through the same delivery point and document the trigger for any maritime policy adjustment.
• Air: Confirm the available departure, chargeable weight and itemized surcharges. Calculate how many units are needed to bridge the inventory gap.
• FBA: Update the fulfillment fee estimate by SKU and keep it separate from inbound and import costs.

FAQ

Can a foreign IOR keep its current broker after January 5?

It depends on the IOR’s CTPAT validation and the broker’s role. A foreign IOR without validation generally needs a licensed, CTPAT-validated broker under the new rule. Ask the broker to confirm the arrangement for your entries and the scope of any approved delay it plans to use.

Can a December sailing still qualify for a Section 301 product exclusion in January?

Yes, if the product meets the exclusion description and the consumption entry or bonded warehouse withdrawal for consumption falls within the stated window. Have your broker confirm the applicable customs date and filing treatment.

Does the maritime fee suspension change my product’s Section 301 duty?

For ordinary merchandise, review the applicable product tariff provisions separately. The maritime notice covers specified transport fees and certain equipment duties under that investigation. If you are budgeting a product exclusion, check the separate USTR product notice and your broker’s filing treatment.

Should I add $0.19 to every FBA SKU in my January forecast?

Use Amazon’s SKU-level estimate. The $0.19 is an average per unit sold, and the actual change varies by product, size and price. Apply each fee on its stated effective date.

Plan Around the Date You Need Inventory