Issue 4. Status as of November 9, 2026. Covers items published or taking effect November 3 to November 9, 2026, plus dates coming up over the next few weeks (U.S. Eastern time).

The one thing to know: CBP’s new rule for foreign importers of record

Status as of November 9, 2026. CBP published an interim final rule, “Heightened Requirements for Foreign Importers of Record,” on November 6 at 91 FR 69977 (Nov. 6, 2026). It takes effect January 5, 2027, and comments are due the same day. When we checked on November 9, CBP had issued filing guidance in CSMS # 70381183 and no later CSMS message on the rule.

What it does. The rule implements Executive Order 14411, “Strengthening Customs Enforcement.” It sets out who counts as a “U.S. importer of record” (IOR) and who is a “foreign IOR.” A foreign IOR that is not CTPAT validated (CTPAT is CBP’s trusted trader program) must use a licensed customs broker that is CTPAT validated to make entry. Licensed brokers must verify that a client qualifies as a U.S. IOR before reporting it as one (Federal Register notice; CBP release).

Who counts as a U.S. IOR. Under new 19 CFR 110.2(a), as CBP describes it, a U.S. IOR is a U.S. citizen or lawful permanent resident, or an entity that is organized under U.S. law, is located in the United States and at all times has either (1) at least 51 percent of its beneficial owners being U.S. citizens or lawful permanent residents who control the entity, or (2) direct ownership of a significant amount of unencumbered U.S. real property. CBP’s FAQ says “significant” means 100 percent of the IOR’s prior-year entered value or $20 million, whichever is greater, and that an entity can qualify without meeting that threshold if it meets the 51 percent test (Federal Register notice; CBP FAQ). CBP says it may ask for records to verify a claim.

What changes on entry filings. CSMS # 70381183 says three new data fields are being added to CBP Form 3461 and CBP Form 7501 and their electronic equivalents: “U.S. Importer of Record,” “Acting on behalf of” and “Principal on Power of Attorney.” It says CBP has built validation checks and “may reject entries and entry summaries” from January 5, 2027, if a foreign IOR files without CTPAT validation or a CTPAT validated broker, or if a non-CTPAT broker acting as IOR does not give the principal when required (CSMS # 70381183). CBP’s FAQ adds that an inaccurate U.S. IOR declaration can lead to penalties, live-entry requirements and loss of immediate delivery privileges (CBP FAQ).

Dates for brokers. Brokers may ask CBP for delayed compliance with the new verification duty by January 5, 2027, and CBP expects all brokers to be fully compliant by May 6, 2027 (Federal Register notice, Section VII).

What it does not do. The rule does not ban informal entries (shipments of $2,500 or less) by foreign IORs. CBP says it will monitor them and may prohibit them later, and it asks for comment on that option (Federal Register notice, Section VI.G).

Related CBP actions. CBP’s page lists two other proposals under the same executive order: an advance notice on supply chain visibility data (comments due December 1, 2026) and a proposed rule on low-value shipments, including bonds for informal entries (comments due December 7, 2026) (CBP page).

What small and medium importers may want to consider. General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

1. If your company is organized and located in the United States and controlled by U.S. citizens or permanent residents holding at least 51 percent, the rule’s test points to U.S. IOR status, and the declaration appears on each entry. Ask your broker how they plan to collect and keep that information.
2. If you use an overseas entity, a foreign-owned U.S. company or a nonresident as importer of record, ask your broker now whether it qualifies as a U.S. IOR under the rule’s tests, and whether the broker is CTPAT validated. CBP publishes a list of validated brokers.
3. Comments can be filed at regulations.gov under docket USCBP-2026-1387 until January 5, 2027.

What to watch. Any change to the January 5, 2027 date, further CSMS messages, and CBP’s promised webinar and reference guide.

Running story: IEEPA refunds

Status as of November 9, 2026. In the class action Freestyle World, Inc. v. United States (CIT Court No. 26-01088), the parties filed a consent motion for a scheduling order on November 5 (ECF No. 67), and the court granted it on November 9 (order, ECF No. 68).

What the court’s order sets. The November 9 order directs the plaintiff to file a motion by November 11 for an order directing CBP to liquidate or reliquidate class members’ entries on which IEEPA duties were deposited. The government must answer the complaint by November 13 and respond to that motion by December 9. By December 14 the parties must confer and propose a way to report on the class action’s progress (order, ECF No. 68).

Dates already set. The government’s short report on CAPE progress is due at 5 p.m. Eastern on Tuesday, November 10, and a closed settlement conference is set for 2 p.m. Eastern on Thursday, November 12 (ECF No. 66). ECF No. 68 does not change those dates.

CBP’s side. CBP’s IEEPA refunds page shows a last-modified date of November 2, and we found no CAPE or IEEPA refund CSMS message between November 3 and November 6 (CBP refunds page).

What it means for you. Nothing in the court’s schedule changes how CAPE works today. Importers with finally liquidated entries may want to ask a trade attorney how the class action, which covers class members, relates to their own claims.

Still pending. The government’s Federal Circuit appeal (No. 26-1895) is undecided; its reply brief was due November 9, and the docket as of November 9 shows nothing newer than October 21 (Fed. Cir. No. 26-1895 docket). In the Section 122 appeal (No. 26-1804), the government’s response and reply brief is due November 12 (Fed. Cir. No. 26-1804 docket).

Deadlines

Date	What	Source
Tue Nov 10, 2026, 5 p.m. ET	Government’s CAPE progress report due at the CIT	CIT order, ECF No. 66
Wed Nov 11, 2026	Plaintiff’s motion on liquidation or reliquidation of class members’ entries due	CIT order, ECF No. 68
Thu Nov 12, 2026, 2 p.m. ET	Closed settlement conference in the IEEPA class action. Same day: government’s response and reply brief in the Section 122 appeal (Fed. Cir. No. 26-1804)	CIT order, ECF No. 66; Fed. Cir. No. 26-1804 docket
Fri Nov 13, 2026	Government’s answer to the class action complaint due	CIT order, ECF No. 68
Mon Nov 16 to Mon Nov 23, 2026	Shopping carts from China at the ITC: requests to appear by noon Nov 16, testimony by 4 p.m. Nov 17, conference Nov 18 at 9:30 a.m. ET, post-conference briefs 5:15 p.m. Nov 23. Cardboard boxes scope rebuttal comments are due 5 p.m. ET Nov 19	91 FR 68969; 91 FR 67276
Mon Nov 30, 2026	Requests for AD/CVD administrative reviews of orders with November anniversary months. Also: comments to Commerce on subsidy programs of countries exporting softwood lumber (Softwood Lumber Act of 2008)	91 FR 68936, FR Doc. 2026-22345; 91 FR 68109 (Oct. 29, 2026)
Tue Dec 1, 2026	Comments due on CBP’s advance notice on supply chain visibility data	CBP page
Mon Dec 7, 2026	Comments due on CBP’s low-value shipments proposed rule	CBP page
Wed Dec 9, 2026	Government’s response to the plaintiff’s motion due	CIT order, ECF No. 68
Mon Dec 14, 2026	ITC preliminary determinations, shopping carts from China (views to Commerce by Dec 21)	91 FR 68969
Sat Jan 9, 2027, 11:59 p.m. ET	End of the further suspension of the Section 301 maritime action. USTR’s notice (FR Doc. 2026-22867, published November 10, 2026) suspends the fees on maritime transport services and the Annex V.A duties on ship-to-shore cranes and intermodal chassis and parts through 11:59 p.m. ET on January 9, 2027, and says no party will accrue liability for or be required to pay them during the suspension. USTR says it will consider before then whether to continue the suspension. Ask your licensed customs broker or trade attorney about your shipments.	FR Doc. 2026-22867; 91 FR 67388; 90 FR 48320 Annex V.A
Tue Jan 5, 2027	CBP’s foreign importer of record rule takes effect; comments due; brokers’ delayed compliance requests due	91 FR 69977; CSMS # 70381183
Fri Jan 29, 2027	2027 customs broker permit user fee of $190.88 due	91 FR 67594
Sun Jan 31, 2027	Licensed brokers’ continuing education deadline for the current triennial period (status report due Feb 28, 2027)	CSMS # 70373554

Carried dates from earlier issues that still apply: quartz quota Nov 15 and polyester fiber quota Nov 23, USMCA review comments Jan 12, 2027, FDA comments Dec 22 and Dec 28, Entry Type 13 on Jan 20, 2027, and the two-year limit for IEEPA suits at the CIT under 28 U.S.C. 2636(i). Details are in Issue 2’s table.

What changed

1. Solar cells from India, Indonesia and Laos: AD and CVD orders issued

Commerce issued antidumping duty orders (91 FR 70862) and countervailing duty orders (91 FR 70843) on crystalline silicon photovoltaic cells, whether or not assembled into modules, from India, Indonesia and Laos, both published November 9. The ITC notified Commerce on November 2 that it made final affirmative injury determinations (91 FR 69865, Nov. 5). The antidumping notice says CBP will require cash deposits at the rates in its company-by-company tables from the Federal Register date of the ITC’s final determinations, except as its Provisional Measures section says. It lists HTSUS 8541.42.0010 and 8541.43.0010 as the current classifications and notes that subject goods may also enter under certain 8501 and 8507 subheadings, but the written scope controls.

What it means for you. If you buy solar cells or modules from these countries, the rate depends on the producer or exporter named in the tables. Ask your broker which rate and scope apply to your supplier.

General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

2. Steel wire garment hangers: Commerce finds circumvention through Cambodia

Commerce made a final affirmative determination that hangers completed in Cambodia from steel wire, or steel wire and paper accessories, produced in China or Vietnam are circumventing the antidumping order on hangers from China and the AD and CVD orders on hangers from Vietnam (91 FR 70055). Commerce says it will continue to suspend liquidation and require cash deposits on unliquidated entries from Cambodia entered on or after August 12, 2025. It found that no exporter of hangers from Cambodia is eligible to certify the origin of the steel or steel and paper inputs, and it set up a certification program for entries made with Chinese rather than Vietnamese inputs, which needs documentation at entry.

What it means for you. If you import hangers from Cambodia, ask your broker how the determination applies to entries since August 12, 2025, and what documentation the certification needs.

General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

3. New AD/CVD cases: wooden fence components and seamless pipe

Commerce started antidumping and countervailing duty investigations of certain wooden fence components from China, on a petition filed September 24 by the American Alliance of Wooden Fence Producers (AD, 91 FR 70851; CVD, 91 FR 70837). It also started antidumping investigations of seamless carbon and alloy steel standard, line and pressure pipe from Georgia and India, and a countervailing duty investigation on India, on petitions filed October 15 by Tenaris USA, Vallourec Star and the union USW (AD, 91 FR 70856; CVD, 91 FR 70847). These are early-stage investigations; no AD or CVD duties are in effect on these goods because of them yet.

What it means for you. If you import fencing or pipe from these countries, the scope descriptions in the notices say what is covered. Ask your broker whether your products may be in scope.

General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

4. AGOA: USTR says the President notified Congress of his intent to terminate South Africa and Rwanda from the program as of January 1, 2027

On November 2, USTR said the President notified Congress and the governments of Rwanda and South Africa of his intent to terminate them from the African Growth and Opportunity Act trade preference program as of January 1, 2027 (USTR statement). We did not find a Federal Register notice or proclamation implementing this when we checked on November 8.

What it means for you. If you import goods from these two countries under AGOA, importers may want to ask their broker how the January 1, 2027 date could affect entries.

General information only, not legal or customs advice. For your situation, talk to a licensed customs broker or trade attorney.

Also this period.

• Mattresses orders continue. Commerce published the continuation of the AD and CVD orders on mattresses from Cambodia, China, Malaysia, Serbia, Thailand, Turkiye and Vietnam, following the ITC finding we noted in Issue 3 (91 FR 70841; 91 FR 67611).
• ACE account mergers. CBP updated the ACE Portal account application on November 5 so account owners can request a merger of ACE accounts, with a signed letter required (CSMS # 70362316).
• Broker deadlines. CBP reminded licensed brokers of the January 31, 2027 continuing education deadline and the February 28, 2027 status report deadline (CSMS # 70373554).

Previous issues

• Issue 3: status as of November 2, 2026 (emailed November 3, 2026)
• Issue 2: status as of October 26, 2026 (published October 27, 2026)
• Issue 1: status as of October 23, 2026 (published October 23, 2026)

Not advice. Importer Weekly is general information only, not legal, customs-brokerage, tax or financial advice. For decisions about your entries, refunds or filings, consult a licensed customs broker or a trade attorney.

How this is made. Produced with AI assistance. Each item links to the official source we relied on; tell us if you spot an error. Questions, tips or corrections? Email hello@importerweekly.com.