Insights
Plain language coverage of US Importer of Record requirements, customs enforcement rulemaking, tariff actions, and customs valuation, written from primary sources.
Importer News Customs Enforcement Importer of Record Tariffs and Trade Policy
Importer of record requirements 2026: what applies today, with dates
The IOR requirements in force on September 30, 2026, each with its source and date: 19 U.S.C. §1484, Form 5106, bonds, nonresident rules, records, Form 5106 voiding since…
Section 232 pharmaceutical duties now apply to all companies as of September 29, 2026
Proclamation 11020 duties on patented pharmaceuticals and ingredients reached all companies on September 29, 2026. CBP CSMS #70054007 sets the Chapter 99 headings, from 100 percent to zero,…
Foreign importer of record requirements: does this apply to me?
Four situations that put a foreign company in the Importer of Record role, the three ways foreign companies handle it, and what the role requires today, from the…
Polysilicon stockpiling rule: weekly limits for importers of record registered after August 6, 2026
A BIS temporary final rule in effect September 22 through December 3, 2026 caps weekly polysilicon entries by importers of record registered with CBP on or after August…
Nonresident importer in the United States: what the rules require today, and what is changing
A nonresident importer needs a resident agent, a bond with a resident surety, and a Form 5106 that names its own address and contacts. Since September 18, 2026…
H.R. 5334 is law: the 30-day clock on Russia and secondary duties has started
The House concurred 262 to 159 on September 16 and the President signed H.R. 5334 on September 18, 2026. Sections 112 and 113 give the President until October…
Who has the right to make entry? The financial interest test, explained
The Importer of Record must hold the right to make entry, and that turns on a financial interest in the goods. What 19 U.S.C. §1484, CBP Directive 3530-002A,…
Canada Section 338 actions: duty lists changed September 15, import exclusions begin September 29
Five proclamations under Section 338 of the Tariff Act of 1930 change which Canadian motor vehicle and alcoholic beverage products carry the additional 50 percent duty from September…
September 18: what CBP’s Form 5106 accuracy enforcement does and does not change
From September 18, 2026, CBP voids Importer of Record numbers whose Form 5106 data is inaccurate. What the August 19 notice requires, what it leaves to rulemaking, and…
H.R. 5334: what the Senate-passed secondary tariff sections say, and where the House vote stands
The House adopted the rule for the Senate amendments to H.R. 5334 on September 15, 2026. What Sections 112, 113, and 115 say about duties of up to…