Since around the Chinese New Year, enforcement by U.S. Customs and Border Protection (CBP) has been continuously tightening. What initially appeared to be routine, phased inspections has rapidly escalated.
Within just two months, 3,826 Chinese containers have triggered 5H inspections, with 3,137 shipments forced to return, resulting in an astonishing 82% return rate. Meanwhile, on March 13, CBP issued another notice announcing a large-scale cleanup of Importer of Record (IOR) numbers starting March 20, signaling even stricter regulatory control.
A sudden regulatory storm is now reshaping the rules of cross-border logistics to the United States. As CBP enforces comprehensive verification of importer identities, the long-standing “DDP (Double Clearance & Duty Paid)” model is on the verge of being eliminated. An era may be coming to an end.
1. Mass Invalidation of IORs: The “Identity” of Customs Clearance Is Being Redefined
At the core of this policy shift is a centralized overhaul of the Importer of Record (IOR) system.
The IOR serves as the unique identity of an importer within the U.S. customs framework, covering the entire process of declaration, taxation, compliance, and liability tracking.
Under the new requirements:
All import declarations must be tied to a real, verifiable IOR
Non-compliant IORs will result in clearance failure, cargo holds, or forced returns
Unlike previous random checks, this is a systematic purge of existing IOR records. Any IOR with:
Incomplete information
Unverifiable entities
Expired or invalid documentation
will be directly revoked.
This effectively eliminates common industry practices such as:
Shared IOR usage
“Borrowed” import identities
Virtual or shell importers
2. Regulatory Logic Upgrade: From “Checking Goods” to “Checking People”
This tightening is not an isolated event, but part of a broader evolution in U.S. import regulation.
Historically, customs focused on cargo compliance. Today, the focus has shifted to importer authenticity and accountability.
In simple terms:
Who is importing and who takes responsibility now matters more than ever.
This shift is driven by long-standing industry issues:
Widespread use of shell or fake importers
One IOR shared among multiple sellers
Undervaluation or misdeclaration to avoid duties
Broken liability chains with no accountability
These practices have turned the DDP model into a high-risk gray-area operation, making it a primary target in this enforcement wave.
3. Fatal Impact on the DDP Model
The essence of the DDP model is that freight forwarders act as the importer (IOR), handling customs clearance and duties on behalf of sellers.
Its advantages have always been:
Low barrier to entry
Lower costs
Operational simplicity
However, under the new regulations, its foundation is collapsing:
IOR must be real and exclusively tied to one entity
Shared or virtual identities are no longer allowed
Clearance responsibility must be traceable
Third parties can no longer “take the blame”
Strict declaration requirements reduce space for underreporting
In short:
The logic of “the forwarder clears customs and assumes responsibility for you” is no longer viable.
4. Chain Reactions: Rising Costs, Delays, and Industry Reshuffle
The impact of these policies will quickly spread across the supply chain:
1) Significant Increase in Clearance Costs
Independent IORs, separate customs bonds, and stricter documentation checks will increase both operational costs and labor input.
2) Pressure on Transit Time
Identity verification (including possible video or on-site checks) will become standard, extending clearance timelines and maintaining high inspection rates.
3) Increased Risk for In-Transit Cargo
Shipments using non-compliant IORs may be:
Blocked upon arrival
Subject to demurrage and storage fees
Forced to return, multiplying losses
4) Accelerated Industry Consolidation
Small forwarders relying on low-cost, non-compliant clearance will be phased out.
Companies with strong compliance capabilities, local resources, and structured service systems will dominate.
5. Compliance Becomes the “Entry Ticket”
This IOR crackdown is only part of a broader regulatory upgrade.
Legislative efforts such as the SAFE Act are reinforcing the direction toward:
Verified local entities
Clearly accountable importers
The trend is unmistakable:
The U.S. market no longer tolerates “no-entity, no-liability” trade models.
6. Urgent Actions for Sellers and Logistics Providers
With a very short policy window, immediate action is required:
For Sellers:
Audit your current IOR for compliance
Ensure complete documentation (CBP forms, EIN, authorization letters, etc.)
Establish a U.S. entity if feasible to control your own import process
For Freight Forwarders:
Immediately discontinue shared or virtual IOR usage
Implement one shipment, one IOR, clear responsibility structure
Strengthen cooperation with licensed customs brokers
Conclusion
From intensified 5H inspections to large-scale IOR cleanups, U.S. import enforcement is escalating rapidly and aggressively.
The message is clear:
The era of low-cost, gray-area DDP logistics is coming to an end.
In the short term, the industry will face inevitable disruptions.
But in the long run, compliance will become the fundamental requirement to access the U.S. market.
For cross-border sellers and logistics providers, this is not just a policy shift—
it is a mandatory transformation for survival.
