For years, many DDP programmes relied on a simple model: the foreign seller (or its forwarder) acts as a non-resident importer of record, files entries through a US broker and pays duties. In 2026 US authorities tightened the rules around exactly that model.
What changed in 2026
- June 2026 order on importers of record. According to Supply Chain Dive's reporting, a presidential order requires importers of record to maintain a minimum level of tangible US assets, bonding or both, and to be in good standing with CBP within 180 days. It also removes informal entry for foreign IORs, so low-value shipments by foreign IORs need formal entries.
- CBP voiding inaccurate IOR records. FreightWaves reported in September 2026 that CBP began voiding IOR numbers with inaccurate or incomplete data. A voided number cannot be used to make entry. Arrangements flagged as exposed include non-resident importers using a broker's address and foreign sellers acting as IOR on DDP sales.
What this means for DDP from Vietnam
| Risk | Practical step |
|---|---|
| IOR record outdated or using a broker's address | Review and update the IOR's address, contacts and bond data in CBP records |
| Bond too small for higher duty levels | Re-size the continuous bond; see customs bonds |
| Low-value shipments previously entered informally | Budget for formal entry costs |
| Foreign IOR unable to meet asset/bond requirements | Consider a US-based IOR (buyer, distributor or service provider) or switch to DAP |
Questions to ask your forwarder
- Who is the IOR on my DDP shipments, and is the record current?
- What bond covers the entries, and is it sufficient?
- What is the fallback if the IOR number is suspended?
Background: what an importer of record is.
Rules are being implemented in stages and challenged in court; confirm current requirements with a licensed US customs broker. We review DDP set-ups for clients shipping from Vietnam and Cambodia — contact us.