Amazon says a new rule for foreign importers is under government review, and sellers should confirm whether their Amazon importer of record is a U.S. or foreign entity before the rule takes effect.
Plenty of overseas Amazon sellers have never checked whose name sits on their U.S. customs entries. That blind spot now has a deadline attached, since the Department of Homeland Security has until November 30, 2026, to rewrite who can act as importer of record.
The timing lands in the middle of Q4 inbound season for brands moving inventory into FBA. Responsibility for the Amazon importer of record stays with the seller even when an Amazon agency manages the account, because the importer of record carries the legal duty for the goods.
Amazon Urges Sellers to Review Their Customs Setup Now
Amazon notified sellers that a rule covering foreign importers of record is under government review and could be implemented quickly. The rule stems from Executive Order 14411, the June 3, 2026 order that directs federal agencies to develop new rules for U.S. imports.
Amazon Services team“Now, a new rule for foreign importers of record is under government review.”
Amazon stated that nothing changes for sellers today and that current import operations continue as usual. The company still recommended that sellers review their customs arrangements now, since requirements will differ depending on whether a seller’s importer of record (IOR), the party officially responsible for importing the goods, is classified as a U.S. or foreign entity.
Sellers whose IOR is classified as foreign could face additional customs requirements tied to assets, bonding, and good standing. Amazon said sellers with a U.S.-based IOR are likely to see fewer changes than those using a foreign IOR.
The speed of the rollout is tied to the regulatory path the rule is taking. The regulation implementing the order reached the White House Office of Management and Budget on September 25 as an interim final rule, a format that can take effect before public comments are collected.
Amazon Importer of Record Status Decides Who Faces the Biggest Changes
U.S. Customs and Border Protection (CBP) has already taken a first implementation step by publishing a general notice on importer of record data accuracy at 91 FR 53627. The notice does not change seller obligations overnight, but it puts the accuracy and accountability of each named importer under closer review.
Many sellers outside the U.S. import through arrangements such as a forwarder’s entity, a supplier’s U.S. affiliate, or a paid service that lends its importer number. The level of exposure under the new enforcement depends on which setup is listed as the Amazon importer of record.
| Import Setup | Exposure |
|---|---|
|
U.S. company with its own importer number
|
Low
|
|
Supplier or forwarder named as importer (DDP)
|
Medium to high
|
|
Foreign company as its own importer
|
High
|
|
Paid third-party importer service
|
High
|
Foreign companies acting as their own importer and paid third-party importer services carry the highest exposure, while U.S. companies with their own importer number carry the lowest. The importer of record for each shipment is listed on CBP Form 7501, the entry summary filed with customs.
Clearance delays during peak season can lead to stockouts and lost sales on affected listings. In a hypothetical example, 4,000 units held for three weeks on a SKU selling 180 units a day at $6.20 of contribution per unit would forgo 3,780 units of demand and $23,436 in contribution before any ranking loss.
CBP Proposes Bonds for Every Informal Entry
Under Executive Order 14411, CBP published a Notice of Proposed Rulemaking that would require bonds for all informal entries. Informal entries are the simplified entry type used for lower-value shipments, and the bond requirement is one of several changes in the proposal.
CBP said the proposal is meant to modernize how low-value shipments are processed across all modes of transportation. It aims to improve data availability and filing timeliness, and it adds a new electronic entry type for international mail shipments.
The public can submit comments during a 60-day period that ends December 7, 2026. CBP’s voluntary electronic Entry Type 13 process for postal shipments, announced in June 2026, remains available and is separate from this proposal.
CBP said the order allows it to set unified standards for all importers, apply stricter requirements to foreign entities, and increase transparency and accountability. The agency added that compliant importers benefit because the reforms raise consequences for transshipment, undervaluation, and misdeclaration.
Foreign Importer of Record Requirements Take Shape Before November 30
Executive Order 14411 gave the Department of Homeland Security 180 days to revise who can serve as importer of record, a deadline that falls on November 30, 2026. Under the text of the order, a company qualifies as a U.S. IOR only if it is organized under U.S. law, located in the U.S., and controlled at all times by U.S. citizens or lawful permanent residents.
A company is considered located in the U.S. when it has its principal place of business, a physical site with significant business activity, and sufficient tangible assets in the country. A U.S. LLC owned by a non-U.S. person would not meet the ownership requirement and would be classified as a foreign IOR.
The order directs CBP to bar foreign IORs from filing informal entries and to require them to be CTPAT-validated or file formal entries through a CTPAT-validated licensed customs broker. All importers, U.S. or foreign, would need to maintain minimum tangible domestic assets or bonding, stay in good standing with CBP, and disclose details such as import volumes, ownership, affiliates, and U.S. assets.
The order’s 90-day measures, which included a penalty floor of at least 50 percent of the assessed penalty outside exceptional circumstances, were due in early September 2026. The 180-day measures are due November 30, 2026, although CBP’s final regulations may set their own effective dates.
