It’s been a busy summer in the world of customs and trade compliance, and we wanted to take a moment to highlight three developments that should be on importers’ radar.
From increased scrutiny of Importer of Record information to new enforcement expectations and tariffs affecting certain Canadian goods, here’s what you need to know.
Is Your Importer of Record Information Up to Date?
CBP is increasing its focus on the accuracy and completeness of Importer of Record (IOR) information.
Beginning September 18, CBP plans to begin voiding IOR numbers when required information on CBP Form 5106 is determined to be incomplete or inaccurate. A voided IOR number cannot be used to enter merchandise into the United States.
What Importers Should Do
Now is a good time to review the information associated with your IOR number, including:
- Company name and identification information
- Mailing and physical addresses
- Phone number and email address
- Other information submitted to CBP through Form 5106
Importers should make sure information provided to CBP is accurate, complete, and directly associated with the Importer of Record.
Read More: CBP to Begin Voiding IOR Numbers for Incomplete or Inaccurate Information
CTPAT Takes on Greater Importance
As CBP moves toward a more enforcement-focused environment, participation in the Customs Trade Partnership Against Terrorism (CTPAT) may become increasingly valuable.
New enforcement initiatives are expected to place greater emphasis on importer vetting and due diligence, particularly when customs brokers represent foreign Importers of Record.
Among the information brokers may be expected to verify are an importer’s identity, ownership structure, business affiliations, U.S. assets, compliance history, import activity, and ability to meet its duty and fee obligations.
For foreign IORs in particular, CTPAT participation could become an important consideration when determining how entries are filed and which customs brokers can represent them.
Read More: CTPAT Validation and the Changing Enforcement Environment
Effective Today: Section 338 Tariffs on Certain Canadian Imports
Importers should also be aware of the 50% Section 338 tariffs scheduled to take effect today, August 19, on certain products imported from Canada.
The measures are expected to affect approximately 5% of U.S. imports from Canada, and importantly, USMCA eligibility does not necessarily protect an affected product from these Section 338 duties.
Negotiations between the United States and Canada have continued, meaning the situation remains fluid. Unless official guidance changes the implementation, however, importers should plan for the tariffs to apply.
If your company imports affected Canadian products, we encourage you to review current and upcoming shipments with your customs team.
Read More: Section 338 Tariffs on Imports from Canada
We’re Here to Help
Customs enforcement and trade policy continue to evolve quickly, and small changes can have significant implications for importers.
Richard Murray & Co. will continue monitoring these developments and sharing information as new guidance becomes available.
If you have questions about your IOR information, CTPAT, Canadian imports, or other customs compliance matters, please reach out to our team. We’re always happy to help you understand how these changes may affect your business.
Contact the Richard Murray & Co. team at customs@richard-murray.com.
