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Quick Answer

CBP has not announced a blanket ban on foreign Importers of Record or legitimate DDP shipping from China to the USA.

Beginning September 18, 2026, CBP states that it will immediately void an IOR number if it determines that the associated Form 5106 information is inaccurate or incomplete. A voided number cannot be used to enter merchandise into the United States.

Separate measures involving foreign-IOR eligibility, domestic assets, bonding, informal entries, risk-based vetting, and expanded supply-chain disclosures remain under development. They should not be presented as final operational rules unless CBP publishes additional regulations or guidance.

Before cargo leaves China, importers should verify the identity and contact information maintained through Form 5106. They should separately confirm the customs bond, direct broker Power of Attorney, entry data, and supporting transaction documents.

What Is Effective—and What Is Still Being Developed?

This distinction matters. Importers should not treat a proposal as an effective regulation, but they also should not wait until cargo reaches a U.S. port to discover that the IOR number or underlying entry structure cannot be supported.

What Is an Importer of Record?

The Importer of Record is the party responsible for using reasonable care to ensure that merchandise is properly entered and complies with U.S. law.

Depending on the product and transaction, the IOR’s responsibilities may include:

• Providing an accurate product description and customs value;
• Determining the correct HTS classification and country of origin;
• Paying duties, taxes, and applicable trade-remedy charges;
• Maintaining import records and responding to CBP inquiries;
• Coordinating requirements administered by agencies such as the FDA, FCC, EPA, or CPSC;
• Addressing additional duties, interest, or penalties identified after entry.

Hiring a licensed customs broker does not transfer these responsibilities away from the importer. The broker files documents as the IOR’s authorized agent, but the IOR remains accountable for the entry.

What Changes on September 18, 2026?

On August 19, 2026, CBP published a notice titled “Accuracy of Importer of Record Data Submitted to CBP.” It announced enhanced procedures for reviewing information submitted through CBP Form 5106, the form used to create or update an importer identity.

Beginning September 18, 2026, CBP will immediately void an IOR number if it determines that the Form 5106 information is inaccurate or incomplete. CBP may also take other enforcement action where appropriate.

A voided IOR number becomes invalid for entering merchandise. CBP will send written notice to the latest email address provided by the IOR and, when applicable, copy the customs broker that last filed an entry for that importer.

The principal Form 5106 identity fields include:

• Importer legal name;
• EIN, Social Security number, or CBP-assigned number;
• Mailing address;
• Actual physical address, if different;
• Email address;
• Telephone number.

Each item must be accurate, complete, current, and directly associated with the IOR. The physical address must genuinely belong to the business or individual. It cannot simply be the address of a registered agent, customs broker, freight forwarder, P.O. box, business service center, or unrelated party. The email address and phone number must also belong directly to the IOR.

Customs brokers submitting Form 5106 information must hold a valid Power of Attorney executed directly with the IOR. They should not substitute contact information supplied by a freight forwarder or unrelated third party.

Read CBP’s official Form 5106 enforcement notice.

What If CBP Voids an IOR Number?

The written notice should explain the basis for the action and what identity-supporting information is required to request reestablishment. The IOR—or a customs broker holding a valid direct POA—may contact CBP at IORProgram@cbp.dhs.gov using the subject line “Enforcing IOR Accuracy.”

Because a voided number cannot be used to enter merchandise, the importer should act promptly and coordinate with its licensed customs broker. A reestablishment request is not a substitute for correcting inaccurate underlying information.

Form 5106 Is Not the Entire Clearance File

An importer’s bond and commercial documents are important, but they are not the same as the identity fields maintained through Form 5106.

First verify the legal name, importer number, physical address, email, and phone number. Then separately confirm that:

• The customs bond is active and sufficient for the anticipated entries;
• The customs broker holds a valid direct POA;
• The commercial invoice reflects the actual transaction;
• The product description, customs value, HTS code, and country of origin are supportable;
• Required product-agency documentation is available;
• The importer can obtain its official entry records, including Form 7501 when applicable.

If an IOR issue prevents an entry from being filed or accepted while cargo is in transit or awaiting clearance, the delay may contribute to storage, demurrage, detention, or other destination charges.

Why Is Importer Identity Receiving More Attention?

Executive Order 14411, signed on June 3, 2026, treats customs enforcement as a national-security, economic, and public-safety priority. It identifies concerns including inaccurate importer information, undervaluation, duty evasion, forced labor, origin violations, intellectual-property infringement, and unsafe or unlawful products.

The policy direction is clear: each entry should connect to an identifiable and accountable party. When the named IOR is inactive, unreachable, unaware of the shipment, or unrelated to the commercial transaction, CBP may have difficulty collecting duties or addressing violations after release.

Form 5106 Accuracy and IOR “Good Standing” Are Different Issues

The September 18 enforcement focuses on whether Form 5106 identity information is complete, accurate, current, and directly associated with the IOR.

Executive Order 14411 separately directs CBP to develop broader good-standing standards, update the IOR registry, remove inactive importers, conduct recurring vetting, and create risk-based importer tiers. It also directs the government to consider changes involving foreign-IOR eligibility, domestic assets, and bonding.

These broader measures are still being developed. Passing a Form 5106 identity review does not necessarily establish that an importer will meet every future eligibility, asset, bond, or good-standing standard.

Read Executive Order 14411.

Why Are Some Customs Brokers Restricting IOR Services Now?

Some customs brokers and logistics providers are tightening their onboarding rules before September 18 because they do not want cargo to arrive under an importer number that may be voided or cannot be independently verified.

Brokers also have their own compliance obligations. A customs broker must obtain authorization directly from the IOR and should not rely on a freight forwarder or undocumented intermediary to substitute the importer’s identity, contact information, or authorization.

Risk increases when one IOR number appears across unrelated sellers and products while the named importer:

• Does not communicate directly with the customs broker;
• Does not know what merchandise is being entered;
• Cannot support the declared value, classification, or origin;
• Cannot obtain entry records;
• Has no documented relationship to the transaction;
• Lacks sufficient bonding or financial security.

For these reasons, some providers are discontinuing shared-IOR, nominee-IOR, or opaque “tax-included” services. That is a risk-control decision by individual providers—not evidence that CBP has prohibited every foreign IOR or every DDP shipment.

Review the Customs Broker Modernization Regulations.

Are Foreign Importers of Record Being Banned?

No blanket rule currently prevents every foreign company from acting as the IOR for every U.S. import.

However, Executive Order 14411 establishes a more restrictive policy direction. It directs DHS and CBP to develop measures involving:

• Minimum tangible domestic assets, bonding, or both;
• Increased minimum bond coverage;
• Additional identity, ownership, affiliation, asset, and anticipated-volume disclosures;
• Enhanced and recurring vetting;
• Risk-based importer tiers;
• Restrictions on foreign IORs filing informal entries.

Not every measure listed in the order has been implemented as a final operational rule. Foreign companies should review their specific structure with a licensed U.S. customs broker or customs attorney rather than assuming either that foreign IORs have been completely banned or that their existing arrangement will remain acceptable without changes.

Is DDP Shipping From China to the USA Still Legal?

Yes. Legitimate DDP shipping remains available. The compliance question is not simply whether a quote or invoice says “DDP.” The real question is whether the underlying importer, authorization, declaration, and duty-payment structure is transparent and lawful.

Before accepting an all-inclusive DDP quote, the seller or buyer should be able to determine:

• Who will be the IOR;
• Whether that party knows about and authorizes the shipment;
• Which licensed customs broker will file the entry;
• What customs value, HTS code, and country of origin will be declared;
• How duties and fees will be calculated and paid;
• Whether the importer can obtain the entry summary and supporting records.

A compliant DDP transaction should not be confused with an opaque arrangement that conceals the importer, declaration, or duty payment. For businesses planning recurring imports, choosing a transparent shipping service from China to the USA can help align transportation milestones with the required customs-document flow.

Who Is the Importer of Record for Amazon FBA Shipments?

Amazon states that the seller—or an eligible entity appointed by the seller—must act as the Importer of Record for inventory entering the United States. An Amazon fulfillment center should not be treated as the party assuming the seller’s customs liability.

Where permitted, a fulfillment center may be shown as the ultimate consignee, but that does not transfer IOR responsibility to Amazon. The seller or another eligible party must establish the importer structure and work with a licensed customs broker and its logistics provider.

Before using Amazon FBA freight forwarding from China, confirm:

1. Who will be listed as the IOR?
2. Has the IOR authorized this specific shipment?
3. Is the IOR number active and the Form 5106 information current?
4. Is the customs bond active and sufficient?
5. Did the broker obtain the POA directly from the IOR?
6. Are the value, product description, HTS code, and origin accurate?
7. Can the IOR obtain the CBP Form 7501 entry summary after filing?
8. Does the product require FDA, FCC, EPA, CPSC, or other agency documentation?

A statement that a forwarder “has a U.S. importer available” is not enough. The seller should understand who that importer is, why the party is eligible, what it has authorized, and whether the entry records will be available.

CBP’s Supply-Chain Visibility Proposal

On September 2, 2026, CBP published an Advance Notice of Proposed Rulemaking titled “Heightened Import Disclosures for Supply Chain Visibility.” The public comment period is scheduled to close on December 1, 2026.

CBP is considering whether importers may eventually need to provide or retain more information about:

• Manufacturers, sellers, shippers, exporters, and other supply-chain parties;
• Foreign export documentation;
• Foreign tax identifiers and Global Business Identifiers;
• Product-level specifications and production information;
• Country-of-origin traceability;
• Earlier submission of entry information;
• Technology used to trace the movement and production of goods.

Importers are not currently required to treat every item in the notice as a new mandatory entry field. Nevertheless, the proposal shows the direction of policy: CBP wants greater ability to compare information supplied by different parties and trace goods from production through U.S. delivery.

Review the official supply-chain visibility ANPRM.

Pre-Shipment U.S. Customs Clearance Checklist

Before cargo leaves China, review the following:

• Active IOR number and accurate Form 5106 information;
• Valid direct broker POA;
• Active customs bond with appropriate coverage;
• Legal manufacturer, seller, and exporter details;
• Commercial invoice and packing list matching the actual transaction;
• Purchase orders and payment records supporting the commercial relationship;
• Accurate product description, customs value, HTS classification, and origin;
• Required safety, labeling, testing, and partner-agency documents;
• Access to entry records, including Form 7501 when applicable;
• Consistent information across the supplier, shipper, IOR, broker, and delivery instructions.

This checklist is a practical preparation tool. It does not mean every data item under consideration in the September 2 ANPRM is already mandatory.

Warning Signs of a High-Risk IOR Arrangement

None of these statements alone proves a violation, but each justifies closer review before shipment.

Frequently Asked Questions

Final Takeaway

The immediate operational change is enhanced enforcement of Form 5106 data accuracy scheduled to begin on September 18, 2026. Broader foreign-IOR eligibility, good-standing, bonding, and supply-chain disclosure measures are developing, but many are not yet final operational rules.

Importers do not need to abandon DDP automatically. They do need to know the real IOR, confirm the broker’s direct authorization, verify the customs bond and entry data, and retain records establishing who made, sold, shipped, imported, and received the goods.