CBP Proposes Requiring Importers to Maintain Records of Foreign Export Documentation

By Erik | September 30, 2026
Editorial illustration of global trade and customs bureaucracy: a vast, dim warehouse-like customs office with towering shelves of paper files, shipping manifests, and stamped documents stretching into the distance. In the foreground, a large wooden desk holds overlapping international shipping documents—commercial invoices, bills of lading, certificates of origin—covered in official stamps, red wax seals, and customs markings in multiple languages, with a magnifying glass resting on top as if under scrutiny. Beyond the desk, blurred cargo shipping containers and a cargo ship are visible through tall windows, along with a world map on the wall with shipping routes traced in red string connecting ports across continents. Lighting is cool and institutional, with dramatic shafts of light emphasizing the towering stacks of paperwork, conveying themes of regulatory scrutiny, international trade documentation, and bureaucratic complexity. Style: photorealistic, high-detail editorial photography, muted navy and gray tones with subtle red accents, shallow depth of field, serious and analytical mood, no visible text or legible writing on any documents.

CBP’s September 2026 advance notice of proposed rulemaking may require importers to obtain, retain, and possibly submit foreign export declarations, invoices, and certificates their suppliers filed abroad, comparing them against U.S. entries to detect undervaluation or transshipment. This article examines the proposal’s practical challenges, legitimate reasons for discrepancies, and how importers should prepare comments before the December 1, 2026 deadline.

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CBP Voiding Importer of Record Numbers on September 18

By Erik | September 2, 2026
A tense customs warehouse at dusk, rows of stacked shipping containers halted before a border checkpoint gate, red warning lights glowing on an official inspection booth, a large digital stamp of a red "VOID" seal hovering translucently over stacked import paperwork and forms in the foreground, a uniformed customs officer reviewing documents on a clipboard near a chain-link fence, cranes frozen mid-motion in the background under an overcast sky, muted blue and gray industrial color palette conveying bureaucratic tension and urgency, photorealistic editorial illustration style, sharp shadows, cinematic lighting, no visible text or logos.

CBP will void importer of record numbers starting September 18, 2026, if Form 5106 data—physical address, email, or phone—doesn’t belong directly to the importer, immediately blocking imports. High-risk profiles include foreign IORs, DDP sales, and drop-shipping using third-party addresses. Importers should verify data and powers of attorney now to avoid stalled shipments.

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You Still Have Options: Recovering IEEPA Tariff Refunds After the CAPE and Protest Deadlines Have Passed

By Erik | August 12, 2026
A wide-angle editorial photograph of a determined importer or business professional standing in a grand federal courthouse corridor, viewed from a low angle looking up, conveying strength and resolve. The figure is dressed in business attire, holding a thick folder of documents, with dramatic natural light streaming through tall arched windows casting long shadows across marble floors. The atmosphere is serious and institutional, with ornate neoclassical architecture visible — columns, high ceilings, and stone walls suggesting the weight and permanence of the legal system. In the background, blurred courthouse doors suggest an open path forward. The overall mood is one of opportunity within a formal, authoritative setting — hopeful but urgent. Cinematic lighting, editorial photography style, shallow depth of field.

The Supreme Court struck down IEEPA tariffs in February 2026, but many importers who missed the CAPE refund window or the 180-day protest deadline wrongly believe they have no recourse. A separate path through the U.S. Court of International Trade under 28 U.S.C. § 1581(i) remains open, offering a two-year statute of limitations — but acting quickly is critical before entry-specific deadlines expire permanently.

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