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Going global: US companies · Nov 9, 2026

CBP Foreign Importer of Record Rule Starts January 5, 2027: CTPAT Brokers, the 51% Ownership Test and What Chinese-Owned U.S. Sellers Should Check

A CBP interim final rule published November 6, 2026 (91 FR 69977) requires foreign importers of record that are not CTPAT-validated to file entries through a CTPAT-validated licensed customs broker starting January 5, 2027. We explain the new U.S. importer of record test (51% U.S. citizen or green card beneficial owners with control, or significant U.S. real property) and what Chinese-owned U.S. companies and cross-border sellers should check now.

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