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The era of “double clearance with tax included” for U.S. shipments has come to an end!

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Time of issue：

2026-03-20 17:29

No sooner has one wave subsided than another arises. In addition to the ongoing Middle East situation, which continues to keep cross-border businesses on edge, a sudden, targeted customs audit by U.S. authorities has further plunged many sellers operating overseas into anxiety.

The U.S. Customs and Border Protection (CBP) has recently officially launched a special document-inspection initiative codenamed “5H,” with the ports of Los Angeles and Long Beach serving as the primary focus areas for this enforcement effort. To date, Over a thousand Chinese export containers have already been temporarily detained due to non-compliant declaration documents, with some even facing mandatory repatriation, resulting in significant losses for sellers.

Meanwhile, on March 13, CBP issued another notice announcing plans for a large-scale clearance on March 20. IOR Number , regulatory oversight has further tightened.

A sudden regulatory storm is completely rewriting the rules of the game for U.S.-bound cross-border logistics. With the U.S. Customs and Border Protection ( Customs and Border Protection ) The comprehensive verification of importers’ identities has been implemented, putting an end to the long-standing practice of “ Double clearance with tax “The ‘model’ is on the brink of being weeded out, and an era may be coming to an end.”

01 Massive IOR failures lead to a revamp of the customs clearance “ID card”

The core of this policy is, It lies in the centralized rectification of the “Importer of Record” (IOR) designation.

As a critical document for U.S. import customs clearance, the IOR serves as the importer’s “unique identifier” within the customs system, spanning the entire process from declaration and tax payment to compliance and liability tracing. Under the new regulations, Effective March 20, all import declarations must be linked to a genuine, verifiable IOR number; otherwise, the declaration cannot be completed and the goods may be detained or returned.

Unlike in the past, this is not a sporadic spot check but a systematic cleanup of a large volume of historical IOR inventory. Any identification number that exhibits issues such as incomplete information, inability to verify the entity, or invalid documentation shall be directly invalidated. This means, The industry-wide practices of “shared IOR,” “affiliated customs clearance,” and “virtual importers” will be completely eliminated.

02 Regulatory Logic Upgrade: Shifting from “Inspection of Goods” to “Inspection of Individuals”

This round of policy tightening is not an isolated incident; rather, it represents a continuation of the ongoing escalation of the U.S. import regulatory regime.

In the past, customs authorities focused primarily on the compliance of the goods themselves; today, The focus of regulation has clearly shifted to the “authenticity of import entities.” In other words, determining who is importing and who bears responsibility is becoming the core principle.

Behind this change lies a long-standing industry problem:

Proliferation of fraudulent or shell importers

An IOR is shared by multiple sellers (“water-running account”).

Underreporting the value of goods and concealing the product name to evade tariffs

The chain of accountability has broken, making it impossible to hold anyone accountable for violations.

The cumulative effect of these issues has transformed the “double-clearance, tax-inclusive” model—from a convenient arrangement into a high-risk, gray-market practice—and made it a primary target of the current round of regulatory crackdowns.

03 The “Dual-Clearance, Duty-Included” Model Faces a Fatal Blow

The so-called “double-clearance with tax included,” Essentially, a logistics provider assumes the role of the Importer of Record (IOR) on behalf of the seller and handles customs clearance and tax compliance as a bundled service. Its core advantages are low entry barriers, low costs, and hassle-free operations.

However, under the new regulations, the very foundation upon which this model relies is crumbling:

The IOR must be genuine and uniquely bound to the principal. , shared or virtual identities are no longer feasible.

Customs clearance responsibility must be traceable. , no longer able to be “backed up” by a third party

Requirements for the authenticity of applications have been raised. , the room for underreporting and concealment has been narrowed.

In other words, the previous logic of “having goods cleared through customs and assuming liability on your behalf” will no longer hold.

04 Chain Reaction: Costs, Timeliness, and the Reshaping of the Industry Landscape

Following the implementation of the new policy, its impact will quickly ripple throughout the entire industrial chain:

1. Customs clearance costs have risen significantly.

Independent IOR, independent Bond (customs bond), and comprehensive document review will significantly increase operational costs. , with both manpower and time投入 increasing in tandem.

2. Logistics timeliness is under pressure

Document verification and identity authentication—including video or on-site verification—have become the norm. , the customs clearance process has been prolonged, and the inspection rate remains at a high level.

3. Concentrated Release of Risks Associated with Goods in Transit

If non-compliant IORs continue to be used, the cargo will be directly detained upon arrival at the port, potentially leading to rapid escalation of demurrage charges, warehouse rental fees, and re-export costs.

4. Accelerated Industry Restructuring

Relying on low prices Grey Customs Clearance Small freight forwarders will be quickly liquidated. Enterprises with compliance capabilities, local resources, and service systems will assume a dominant position.

05 Compliance Has Become the “Ticket to Entry,” Marking a New Phase for the Industry

It is worth noting that, This IOR inspection is merely part of a broader regulatory upgrade. Higher standards for importer qualifications are being further advanced through legislative measures. , such as the SAFE Act and other related legislation, The regulatory approach of “local entities + responsible parties” has been clearly strengthened.

The future trend is already very clear: The U.S. market no longer tolerates a trade model characterized by “no principal, no liability.”

06 Emergency Response: The Practical Choices for Sellers and Freight Forwarders

Given the extremely short policy window, all parties must act swiftly:

For sellers:

Immediately verify the source and compliance of IOR.

Ensure that all documentation is complete (CBP registration form, EIN documents, power of attorney, etc.).

Enterprises that meet the relevant conditions should establish a U.S.-based entity to independently control the customs clearance agent.

For freight forwarders and logistics providers:

Completely disable shared and virtual IOR

Establish an operational system featuring single-ticket, single-clearance processing and clear entity accountability.

Strengthen cooperation with licensed customs brokers to ensure the stability of compliant clearance channels.

Writing to the end

From 5H Inspection With the IOR crackdown now in full swing, U.S. import oversight is continuously escalating at a “high intensity and fast pace.” The signals emanating from this storm are already unmistakable:

The era of “double-clearance, tax-inclusive” services driven by low prices and operating in gray areas is coming to an end.

In the short term, growing pains are inevitable; however, in the long run, Compliance will become the fundamental entry threshold for accessing the U.S. market. For cross-border sellers and logistics enterprises, this is not merely a policy shock—it is a “survival transformation” that must be accomplished.

Opportunities and risks coexist!