Free tool · For entries starting January 5, 2027
Importer of Record Check
Find out how CBP’s new rule applies to you and what to check before filing
From January 5, 2027, a foreign importer of record must be CTPAT-validated or use a CTPAT-validated customs broker, and CBP Forms 3461 and 7501 get three new fields about who the importer is. Answer a few plain-language questions to see whether you are likely a U.S. or foreign importer of record under the new rule, who can be named and who can file, and what to put in the new fields.
Free with an account. No credits, no uploads, no ID numbers.
What this tool checks
- Whether you, or the client on your broker’s power of attorney, likely qualify as a U.S. importer of record under 19 CFR 110.2.
- Whether your entry is covered: formal consumption entries, and informal consumption entries filed on CBP Form 3461 or 7501, including withdrawals for consumption from a warehouse or foreign-trade zone.
- Who may be named as importer of record and who may file, including CTPAT validation of the importer and the broker.
What you’ll get
- A preliminary result: likely U.S., foreign, or needs review, and why.
- What your planned filing setup needs, what blocks it, and what to confirm.
- The values for the three new CBP fields and CBP’s rejection checks.
- A preparation checklist and examples of supporting records for your result.
See a sample result
Fictional examples, run through the same rules as the real check.
- U.S. business
A U.S.-owned company that uses a broker to file, while the company stays named as importer of record.
- Foreign business
A foreign purchaser that is not CTPAT-validated, whose filing broker is not validated either.
- Broker listed as importer
A qualifying U.S. client whose broker is not CTPAT-validated acts as importer of record, with a Form 5106-linked importer number ready.
Your answers stay in this browser tab and are not sent anywhere unless you choose to save the result to your account. Based on the interim final rule 91 FR 69977 and CBP CSMS #70381183, with preparation and verification guidance from the CBP IOR reference guide.