What apparel buyers and suppliers need to know
Apparel companies operating under Delivered Duty Paid (DDP) terms should review their US import arrangements before the CBP rule takes effect on January *, ****. Published on November *, ****, the rule requires foreign vendors acting as Importers of Record (IORs) to be Customs Trade Partnership Against Terrorism (CTPAT)-validated or designate a CTPAT-validated, licensed customs broker to make entry. Where the foreign principal is neither the owner nor purchaser of the merchandise, the broker must act as the IOR. Brands should identify the IOR for each programme and assess whether alternative Incoterms, such as Free on Board (FOB), Free Carrier (FCA) or Delivered at Place (DAP), are more appropriate where suppliers currently manage US importation. US affiliates should verify that their entities meet CBP**;s US-IOR eligibility criteria, as a US address alone is insufficient. All parties should review documentation requirements, discuss potential brokerage charges and consider submitting comments on the rule by January *, ****.
New entry rules for foreign IORs and declarations for US IORs
