Free tool · For entries starting January 5, 2027
Sample result: U.S. business
Straightforward ITC · Importer of Record Check
Preliminary screening · Sample answers · For entries starting January 5, 2027
Sample result: U.S. business
A U.S.-owned company that uses a broker to file, while the company stays named as importer of record. 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?
- Yes
- Is this business actually based in the U.S.?
- Yes, it is based and operates in the U.S.
- Is at least 51% of the company beneficially owned by U.S. citizens or lawful permanent residents who control it?
- Yes
- Does the business maintain that ownership and control at all times?
- Yes
- 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
1.Your preliminary result
Likely a U.S. importer of record
What drove this result
- The company is organized under U.S. law.
- The company is based and operates in the U.S. CBP can verify this by looking at the company’s actual operations.
- At least 51% of the company is beneficially owned by U.S. citizens or lawful permanent residents who control it, at all times.
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 permitted, subject to the items to confirm
- Named as importer
- You (the U.S. importer)
- Files the entry
- Your licensed customs broker
A qualifying U.S. importer can stay named as importer of record and either file itself or use any licensed customs broker. CTPAT validation is not required.
Next step: Send your broker the records that support your U.S. status so it can verify before filing.
Confirm before filing
- At both entry and entry summary, the U.S. qualification must be declared. On the electronic forms this is a Yes/No indicator.
- Before declaring U.S. status for you, the broker must request and review records showing you qualify, for example current governing documents showing U.S. organization, evidence of U.S. operations, ownership and control records for the beneficial owners. Verification continues throughout the broker–importer relationship. The broker keeps records of each verification for five years from its date. Share supporting records with your broker.
- The broker needs a valid power of attorney from the client before transacting customs business, including when it acts as importer of record.
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.
Qualifying U.S. importer is named, self-filed or broker-filed
- U.S. Importer of Record
- Y
- 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 |
|---|---|---|---|
| Qualifying U.S. importer is named, self-filed or broker-filed | Y | 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
Does not apply to your selected setup
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.Key dates and what else to know
Broker verification timeline
- Brokers can ask CBP to delay only their duty to verify a client’s U.S. status. Submit the request by January 5, 2027, and explain why the delay is needed.
- A broker cannot request a delay if it is currently subject to removal from CTPAT, revocation of its Form 5106 filing privileges, federal suspension or debarment, suspension of its entry filer code, or license revocation proceedings.
- A request is not an approval. If CBP approves it, the broker must keep making satisfactory, good-faith progress toward compliance.
- CBP expects every broker to be in full compliance no later than May 6, 2027.
- The delay does not postpone the January 5, 2027 filing fields or the CTPAT requirements.
Broker verification continues throughout the broker–importer relationship. Tell your broker about changes in ownership, control, U.S. operations, property or supporting assets. Brokers keep records of each U.S. status verification for five years from the verification date and provide them to CBP upon request. CBP’s guide does not prescribe a fixed review interval.
If CBP determines that a U.S. declaration was inaccurate, it can require live entry (paying estimated duties before release) and discontinue immediate delivery privileges, for formal and informal entries.
5.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.
- Before claiming U.S. status, gather records supporting each qualification condition and keep them available for your broker or CBP. Resolve any open status questions first.
Supporting records for your result
These are examples to discuss with your broker or CBP as relevant to your circumstances. Gather records for each condition you rely on to claim U.S. status.
- U.S. organization: current formation documents and Secretary of State records showing this specific entity is organized under U.S. law.
- U.S. operations: local business licenses, a Certificate of Occupancy, leases, utility bills, insurance, invoices or purchase orders showing the business address, and warehouse evidence. A lease can support location; it does not establish direct property ownership.
- Profit and capitalization: revenue records, tax returns, managerial accounts, business plans, bank loans or lines of credit.
- U.S. beneficial ownership and control: shareholder ledgers or agreements, stock certificates, corporate resolutions, organizational charts and tax returns. Confirm that compensation and distributions match reported ownership stakes and that there are no undisclosed side agreements affecting ownership or control.
- Physical domestic assets, as relevant: historical U.S. bank and TreasuryDirect statements; warehouse, inventory-system or third-party logistics records; and equipment titles, purchase and financing records, lien releases, valuations and remaining useful-life information.
- Asset records should demonstrate a continuing U.S. presence consistent with the business’s operations and financial statements. Assets recently acquired solely to qualify, without an intention to keep them in the U.S., warrant further review.
- Quickly sold or perishable inventory and equipment near the end of its useful life may be insufficient. These are case-by-case considerations, not automatic disqualifiers or fixed dollar thresholds.
- Brokers should verify claimed assets using supporting evidence. If concerns remain, they should request more information and, if unresolved, decline to verify U.S. status or decline the business relationship.
Want a wider look at a specific product or shipment? Try the Import Readiness Check.