Non-Resident Importer Onboarding Checklist

Updated June 2026

Everything a foreign company needs to become a U.S. importer of record — and what the June 2026 enforcement order changed.

Who this is for

You are a company based outside the United States, and you want to be the importer of record for your own U.S. shipments — selling delivered-duty-paid, holding inventory in a U.S. fulfillment center or Amazon facility, or controlling your own classification and valuation instead of pushing customs onto your buyer. This is the document checklist your customs broker needs to set you up, in the order it is needed.

1. Company identity

• Legal company name, exactly as registered in your home country.
• Full registered business address (no P.O. box for the physical address).
• Certificate of incorporation / business registration document.
• Responsible officer: name, title, email, and phone for customs matters.
• U.S. EIN if you already have one — otherwise you will use a CAIN (next section).

2. Importer of record number — EIN or CAIN

You cannot file a U.S. entry without an importer number. Pick your path:

• CBP Form 5106 (Create/Update Importer Identity Form) — completed and signed.
• CAIN requested on the form if you have no U.S. tax ID.

3. Broker authorization

• Signed customs power of attorney (POA) authorizing your licensed U.S. customs broker.
• 2026: Confirm your broker is a CTPAT-validated, licensed U.S. customs broker — under the new rules this is one of the two ways a foreign IOR's entries can be filed.

4. Customs bond

• Bond application data for your surety (entity details, estimated annual duties).
• 2026: Do not assume a standard continuous bond. Decide with your broker between a CBP-approved continuous bond (with revenue-protection evidence), a properly sized single transaction bond per shipment, or asset-backed coverage.
• Expect higher minimum bond amounts than the historic $50,000 continuous-bond floor.

5. Product & classification

• Product catalog / list of SKUs you intend to import.
• 10-digit HTS classification for each product (or product specs so your broker can classify).
• Material composition, function, and use for each product (drives classification).
• Any FDA / USDA / EPA / CPSC regulatory status (drives PGA filings — see section 8).

6. Country of origin

• Country where each product was manufactured or substantially transformed.
• Manufacturer name and address.
• Origin support: mill certs, bill of materials, manufacturer affidavit, or production records.
• If claiming USMCA or another trade-agreement rate: certification of origin with all data elements.

7. Customs valuation

• Commercial invoice format showing the transaction value you will declare.
• Whether buyer and seller are related parties (affects valuation method and scrutiny).
• Terms of sale / Incoterms (DDP, FOB, etc.) — these change who declares what.
• Any assists, royalties, or commissions that must be added to declared value.

8. Participating government agencies (if applicable)

• FDA: facility registration and prior notice for food, drugs, cosmetics, devices.
• USDA / APHIS: permits for agricultural and plant/animal products.
• EPA: compliance for chemicals, engines, refrigerants.
• CPSC: testing and certification for consumer products.

9. Logistics & consignee

• U.S. ship-to / consignee details (3PL, fulfillment center, Amazon facility, or buyer).
• Who owns the goods at the moment of entry (important for marketplace and 3PL flows).
• Packing list format and expected first-shipment timing.
• Port of arrival and mode (ocean / air) — affects fees and filing windows.

10. Recordkeeping

• Owner of the import audit file inside your company.
• Plan to retain entry records, classification rationale, valuation support, and CBP correspondence for five years.

The setup sequence at a glance