As of 28 September 2026, U.S. Customs and Border Protection (CBP) has significantly heightened its enforcement focus on non-resident Importers of Record (IOR) shipping goods into the United States. This development, analyzed by PwC Italy’s customs and trade specialists, directly affects Italian and European exporters who act as IOR for their U.S. customers without a physical U.S. presence. CBP is now demanding enhanced documentation to verify the identity, financial solvency, and compliance history of foreign IORs, including power of attorney records, customs bond sufficiency, and evidence of reasonable care practices. Failure to meet these heightened requirements can result in shipment holds, penalties under 19 U.S.C. § 1592, and potential revocation of IOR privileges.
Key Takeaways
- Enhanced Due Diligence Obligations: Foreign IORs must now maintain comprehensive compliance programs, including periodic internal audits, classification validation (HTSUS), and valuation methodologies aligned with the WTO Valuation Agreement.
- Customs Bond and Financial Guarantees: CBP is scrutinizing the adequacy of continuous customs bonds (Activity Code 1) for non-resident IORs, often requiring higher bond amounts or additional collateral to mitigate revenue risk.
- Strategic Alternatives for Exporters: Italian companies should evaluate alternative models such as using a U.S. resident IOR (e.g., a customs broker or subsidiary), leveraging Section 321 de minimis entries for low-value shipments, or establishing a U.S. legal entity to assume IOR responsibilities.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement