3,826 containers were inspected and 3,137 were forcibly returned. The "double clearing and tax-guaranteed" model of the US line is coming to an end.
Sunny Worldwide LogisticsIt is a logistics company with more than 20 years of transportation experience, focusing on markets such as Europe, the United States, Canada, Australia, and Southeast Asia. It is more of a cargo owner than a cargo owner~
![]()
Recently, the U.S. Customs has continued to escalate its supervision of imported goods, and a series of new regulations and special actions are reshaping the compliance landscape of U.S. Line Logistics.
According to industry data,In the past two months, 3,826 Chinese export containers have triggered 5H special inspections, of which 3,137 were forcibly returned, with a return rate as high as 82%.At the same time,The U.S. Customs and Border Protection (CBP) announced that it will launch a large-scale cleanup of importer record numbers starting from March 20, and the signal of regulatory tightening has become increasingly clear.
This dual regulatory upgrade centered on the 5H inspection storm and IOR number rectification,We are blocking the gray operation path from the source that relied on "shared customs clearance identity" to achieve low-cost customs clearance.
Importer identity authentication is fully tightened, and IOR numbers enter the countdown to cleanup
The core of this policy adjustment is the centralized rectification of the Importer of Record (IOR). IOR is the core voucher in the U.S. import customs clearance system. It is equivalent to the importer's unique identity in the customs system and runs through the entire process of declaration, tax payment, compliance review and responsibility traceability.
According to a notice issued by CBP on March 13,Starting from the early morning of March 20, all import declarations must be bound to a true and verifiable IOR number, otherwise customs clearance will not be completed and the goods may face detention or forced return.
During the inspection, CBP found that the data submitted by some importers in the declaration form contained untrue information and ambiguous subjects, which hindered the customs from accurately verifying the identity of the IOR, and may even involve circumventing legal requirements or financial responsibilities.
It should be noted that not all IOR numbers will be automatically invalidated. CBP has sent formal notices to importers with data accuracy issues, requiring them to supplement or correct information before March 20. If the importer wants to retain the validity of the IOR number, he must submit the following materials through a licensed customs broker:
-
The updated CBP Form 5106 ensures that all required field information is accurate and verifiable;
-
IOR’s valid government-issued photo ID;
-
Documents issued by the IRS proving ownership of the IOR number must clearly show the Employer Identification Number (EIN) and company name;
-
A valid power of attorney between the importer and the licensed customs broker.
CBP said that depending on the situation, importers may be required to conduct on-site or virtual identity verification at the port of entry to further verify the authenticity of the documents. For importers who fail to submit information before the deadline, their IOR number will be officially invalidated, and all import declarations using this number will not be able to pass customs clearance.
The "Double Clearance and Tax Package" model encountered a fatal impact
The most profound impact of this new policy on the cross-border logistics industry is the systematic attack on the "double clearing tax package" model. The so-called "double clearance and tax package" means that the logistics provider takes on the role of importer on behalf of the seller and handles customs clearance and tax matters in a unified manner.
The core advantage of this model is to reduce the entry threshold and operating costs for sellers, but its operation is based on gray operations such as "shared IOR", "affiliated customs clearance" and "virtual importer".
Under the new regulatory framework, the survival basis of this model is disintegrating:
-
The IOR must be truly and uniquely bound to the entity subject, and shared or virtual identities are no longer legal;
-
Customs clearance responsibilities must be traced back to the real importer, and a third party can no longer “cover” for you;
-
The requirements for the authenticity of declared information have been significantly increased, and the operating space for underreporting and concealment has been drastically reduced.
This means,The operational logic of “goods clearing customs on your behalf and taking responsibility for you” that was prevalent in the industry in the past will no longer hold true.Every cargo owner entering the U.S. market needs to establish or clarify his or her true importer identity and assume corresponding compliance responsibilities.
Chain reaction: Cost, timeliness and industry structure are accelerated to reshape
With the implementation of the new policy, the impact is accelerating to the entire industry chain:
Customs clearance costs have increased significantly.
Independent IOR, independent customs deposit and complete document review process will significantly increase the operating cost of a single shipment of goods. Manpower investment and compliance review time are rising simultaneously, and the model that originally relied on economies of scale to reduce costs is facing challenges.
Logistics timeliness is facing greater pressure.
Data verification and identity verification have become the norm, the customs clearance process has been significantly lengthened, and the 5H inspection rate continues to remain high. For time-sensitive cross-border e-commerce goods, this means higher inventory pressure and performance uncertainty.
The risks of goods in transit are concentrated and released.
If you still use non-compliant IOR declaration, the goods will be intercepted directly after arriving at the port. Demurrage fees, warehouse rent and return shipping costs may quickly increase, and some sellers have begun to face the dilemma of "the goods have arrived but cannot be cleared".
The industry is reshuffling at an accelerated pace. Small freight forwarders that rely on low-priced gray customs clearance will be cleared quickly, and companies with compliance capabilities, local resources and a complete service system will dominate the new round of competition.
The time window left for the industry is closing
There are only a few days left before the IOR cleanup deadline on March 20, and there is little time window left for the industry to adjust. For sellers and freight forwarders who are still waiting and watching, the most urgent task at the moment is to immediately initiate compliance self-inspection to verify the authenticity and validity of existing IOR sources to ensure that the data is complete and the subject is clear.
In the longer term, the continued upgrading of U.S. import regulations sends a clear signal:The era of "double clearing and tax package" driven by low prices and gray operations is coming to an end.This regulatory storm is not a temporary move, but a systemic overhaul of long-standing trade compliance issues. In the future, compliance will become a basic threshold for entering the US market, rather than an option.
For cross-border sellers, establishing their own US entity and independently controlling customs clearance entities will be the ultimate solution to completely avoid risks. For logistics companies, strengthening compliance capabilities and building a transparent operating system will become the foundation for a new round of industry reshuffle. Pains are inevitable, but only by completing this "survival transformation" can we win long-term certainty in a more standardized market environment.
