On November 6, 2026, US Customs and Border Protection (CBP) issued an interim final rule strengthening the requirements for companies acting as importers of record (IORs), particularly foreign-owned companies and foreign IORs. The rule, which implements Executive Order 14411, “Strengthening Customs Enforcement,” will take effect January 5, 2027. Comments from stakeholders are also due January 5, 2027. Summary The interim final rule introduces significantly stricter criteria for entities to qualify as US IORs. Under the…