Free tool · For entries starting January 5, 2027
Sample result: Foreign business
Straightforward ITC · Importer of Record Check
Preliminary screening · Sample answers · For entries starting January 5, 2027
Sample result: Foreign business
A foreign purchaser that is not CTPAT-validated, whose filing broker is not validated either. These are fictional sample answers run through the same rules as the real check. They are not about you.
Your answers
- Are you importing as an individual or through a company?
- Through a company or other entity
- Is this company currently organized under U.S. law?
- No
- How will you clear the goods for use or sale in the U.S.?
- Formal entry for consumption
- Whose name will be listed as importer of record?
- Mine or my company’s
- Who will file the entry?
- A licensed customs broker will file it
- Is this exact importer already CTPAT-validated as an importer?
- No
- Does this importer own or buy the goods being imported?
- Yes, it owns or is purchasing the goods
- Is your customs broker CTPAT-validated?
- No
1.Your preliminary result
Likely a foreign importer of record
What drove this result
- The company is not organized under U.S. law. Registering to do business in a U.S. state does not change where a company is organized.
If CBP verifies a U.S. declaration, the appropriate CBP Center Director decides whether the importer qualifies.
2.What this means for your entry
Entry: A formal entry for consumption is covered by the new rules, including a withdrawal for consumption from a bonded warehouse or foreign-trade zone.
This filing setup is blocked
- Named as importer
- You
- Files the entry
- Your broker (not CTPAT-validated)
This setup is not permitted. A licensed broker alone is not enough to file for a foreign importer that is not CTPAT-validated. The broker must also be CTPAT-validated.
What blocks this plan
- Your filing broker is not CTPAT-validated.
Next step: Switch to a licensed customs broker that is CTPAT-validated, or confirm your current broker’s validation.
The existing rules on who has the right to make entry still apply. This rule adds requirements on top of them.
3.New CBP filing fields
From January 5, 2027, CBP Forms 3461 and 7501 and their electronic equivalents carry three new fields. Use the form that applies to your entry. Values below are based on the facts you selected and depend on your U.S. status being confirmed.
This describes the plan you selected, which is blocked. It is not ready to file.
Foreign importer is named (your proposed setup, which is not permitted)
Blocked plan: not filing-ready
- U.S. Importer of Record
- N
- Acting on behalf of
- N
- Principal on Power of Attorney
- Not required by this update
| Selected filing setup | U.S. Importer of Record | Acting on behalf of | Principal on Power of Attorney |
|---|---|---|---|
| Foreign importer is named (your proposed setup, which is not permitted)Blocked plan: not filing-ready | N | N | Not required by this update |
“Acting on behalf of” is Y only when a customs broker lists itself as both filer and importer of record for a client. When it is Y, “U.S. Importer of Record” follows the client’s status, not the broker’s. “Not required by this update” refers only to the new principal number field. On paper forms the U.S. declaration is a checkbox; electronic filings use Yes/No.
CBP’s stated rejection checks, at entry and entry summary
Rejection risk: foreign importer without CTPAT validation
Applies to your plan
From January 5, 2027, CBP may reject an entry or entry summary when a foreign importer files without being CTPAT-validated or without a CTPAT-validated customs broker.
Rejection risk: missing principal number
Does not apply to your selected setup
From January 5, 2027, CBP may reject an entry or entry summary when a broker that is not CTPAT-validated acts as importer of record and does not provide the principal when required.
4.Prepare before filing
- Confirm that the named importer’s CBP Form 5106 and filing information are accurate and up to date.
- If using a broker, ensure it holds an accurate, current power of attorney before any customs business, including when it acts as importer of record.
- For a foreign-importer filing path, keep evidence of the exact importer’s completed CTPAT validation or confirm the broker’s completed validation, as required by the filing plan above. Certification or a pending application alone is insufficient.
Want a wider look at a specific product or shipment? Try the Import Readiness Check.