New US Importer of Record Rules and Your Amazon Stock in 2026

In brief: Amazon has asked sellers who ship to its US warehouses to check their importer of record status in 2026. A US executive order could toughen the rules for importers based abroad. The importer of record (IOR) is the business legally responsible for a shipment and the US duty on it. Since 18 September 2026, US Customs and Border Protection (CBP) has been checking IOR details on Form 5106. The order gives officials until 30 November 2026 to rewrite who can import, and Amazon's own fees don't change.

What Amazon's 2026 importer of record notices say

Date	What happened
3 June 2026	The US President signed Executive Order 14411 on customs enforcement
17 August 2026	Amazon asked sellers to check whether their IOR is a US or foreign business
18 September 2026	CBP began verifying six fields on Form 5106, the form that registers an importer with US customs. Bad data can get an IOR number cancelled
1 October 2026	Amazon confirmed the Form 5106 checks
30 November 2026	180 days after the order: the deadline for officials to revise importer eligibility

Amazon has since emailed sellers that a rule for overseas importers is under US review and could start at short notice. The IOR could be your own business, your freight forwarder or a customs broker.

What the foreign importer of record rules could change

A foreign IOR is one based outside the US. A UK company importing in its own name would probably count, but the final definitions aren't published yet. The order directs US officials to:

• make every IOR hold US assets, a customs bond, or both, at a level CBP sets, and raise minimum bond cover
• stop foreign IORs using informal entry, the simpler route for lower-value shipments
• stop most foreign IORs relying on a continuous bond (one annual bond for all entries) for formal entries
• require foreign IORs to hold CTPAT validation, CBP's supply-chain security programme, or file through a CTPAT-validated licensed broker
• bar any IOR that isn't in good standing with CBP, judged on its compliance and payment record

A worked example

Illustrative figures only: use your own broker's quote.

A UK seller restocks US FBA monthly. Its forwarder now quotes $450 a shipment for a single-entry bond (cover for one shipment) and broker filing.

• 1,200 units a shipment: $450 ÷ 1,200 = $0.375 a unit
• 400 units a shipment: $450 ÷ 400 = $1.125 a unit
• 12 shipments a year: 12 × $450 = $5,400 a year

Small shipments cost three times as much per unit.

What it means for your bookkeeping

• These costs sit outside your Amazon settlement. Duty, bond and broker charges come on your forwarder's or broker's invoices, not the amazon.com payout. Enter them as supplier bills, or your US margin will look too good. Our FBA bookkeeping guide covers where stock costs go.
• Treat them as landed cost. Import duty and inbound freight usually form part of what your stock cost, released to cost of sales as units sell. A per-shipment bond charge may fit the same treatment. Agree the approach with your accountant.
• US duty isn't VAT. Customs duty can't be reclaimed on your UK VAT return, so keep it off any reclaimable tax code. See Amazon VAT tax codes in Xero. Take any VAT on a broker's services from its invoice.
• Collateral isn't an expense. A cash deposit to a bond provider, or assets held in the US to qualify, belongs on the balance sheet. Only the premium or fee is a cost.
• Keep the paper trail. Save your forwarder's written answer on IOR status, your Form 5106 details and each shipment's entry papers. They back up your stock valuation and any CBP query. Reconcile the US payout as in our settlement reconciliation guide.

Do you need to do anything?

1. Ask your forwarder or broker, in writing, if your IOR counts as US or foreign and how it will pass the new tests.
2. If you are your own IOR, check your Form 5106 details.
3. Get a revised landed cost quote before 30 November 2026 and re-price thin-margin US lines.

How TrueBooks helps

TrueBooks imports every Amazon settlement into Xero and keeps each marketplace in its own currency. Analytics show profit and fee ratios by marketplace, so US margins stay separate from UK ones. See how settlements post to Xero.