New Importer of Record Requirements

“Strengthening Customs Enforcement”

On June 3, the White House issued an Executive Order entitled “Strengthening Customs Enforcement“. This order set new requirements for information required to be provided by a U.S. Importer of Record (“IOR”), and greatly increased requirements for Foreign IOR’s.

This order also included a requirement to “update the IOR registry” to remove inactive IOR’s and ensure that all IOR’s have current and complete information on file with CBP.

On August 18, CBP announced new requirements in the Federal Register for all IOR’s to ensure that information provided on Form 5106, which is the form used to provide information about an importer to CBP, is current and complete. As of September 18, CBP may void the IOR number of an importer who’s information on file with CBP is inaccurate. This would render that importer unable to import until a new form is submitted and approved by CBP.

So, what does this mean for you?

  • If you have not imported in a long time, it would be a good idea to check the form 5106 information CBP has on file, and update it if necessary before any shipment proceeds. We can assist with that.
  • If you have been importing, or plan to import, on a DDP basis, where the foreign seller acts as IOR, this may no longer be possible. Check with the seller before any shipment to avoid customs delays and related costs. Note that if a change in shipment terms from DDP to another INCOTERM is called for, we may be able to arrange the clearance ….. or transport from origin. Ask us for a quote!

As always, American Cargoservice is committed to providing valuable updates to our customers. We will continue to monitor the situation, and send out updates as they become available.

Give us a call or email today to see how we can assist.


Steel, Aluminum & Copper Tariff Changes Effective April 6, 2026

Significant changes to Section 232 tariffs on aluminum, steel, and copper articles and their derivatives will take effect at 12:01 a.m. ET on April 6, 2026.

What Changed?

The most important update is how tariffs are calculated.

Previously, duties applied only to the metal content of derivative products.
Now, tariffs will be assessed on the full customs value of the imported product, regardless of how much metal it contains.

This change may significantly increase total duty costs for many importers.


New Tariff Rates at a Glance

  • 50% on aluminum and steel articles, most copper articles, and certain derivatives (Annex I-A)
  • 25% on other copper articles and select aluminum and steel derivatives (Annex I-B)
  • Reduced UK rates:
  • 25% (Annex I-A)
  • 15% (Annex I-B)
    (Requires qualifying melt/pour or smelt/cast processes in the UK)
  • 10% rate for derivative articles made entirely with U.S.-processed metals
  • 200% tariff on Russian-origin aluminum remains unchanged

Transitional Treatment (Through December 31, 2027)

Certain products listed in Annex III will follow a transitional structure:

  • Combined duty capped at 15%
  • If the standard duty rate is already 15% or higher, no additional Section 232 duty applies
  • Beginning January 1, 2028, these products will shift to the standard 25% rate

Additional Key Updates

  • The process for adding derivative products to tariff coverage has been restructured
  • The Secretary of Commerce and U.S. Trade Representative now jointly determine product inclusion
  • This authority now explicitly includes metal containers, even when filled with non-metal goods
  • Manufacturing drawback is available for certain derivative articles from Trade Agreement Partners, including:
  • UK, EU, Japan, Korea, Mexico, Canada, and others
    (Conditions apply based on origin of metal content)

Need Help Navigating These Changes?

These updates may impact duty exposure, sourcing decisions, and compliance requirements.

American Cargoservice works closely with clients to evaluate shipping strategies, documentation, and cost implications in response to regulatory changes.

👉 Contact Us to discuss how these changes may affect your shipments.


The full proclamation text and annexes are available through official government sources.

American Cargoservice will continue to monitor developments and provide updates as they become available.