CBP Tightens Scrutiny of Delivered Duty-Paid Imports
CargoTrans warns US importers to reconsider delivered duty-paid shipping as Customs and Border Protection increases enforcement against foreign importers of record.
Updated on Nov. 5, 2026 in International Trade
Live Poll
Do you expect the prices of imported goods to rise in your area?
CargoTrans advised US buyers to reconsider delivered duty-paid (DDP) shipping arrangements as Customs and Border Protection intensifies scrutiny of foreign importers of record. Some buyers have reported shipments being refused entry, seized, or ordered for re-export.
Why it matters
CBP is investigating whether DDP arrangements are being used to avoid tariffs, and the agency is increasingly relying on customs data analytics through the ACE system to make decisions. The post-Liberation Day rush toward DDP arrangements is beginning to reverse as compliance and financial risks grow for US buyers.
Section 338 revisions took effect 30 October, adding 100 tariff classifications and removing 22 at a 50% additional duty on Canadian goods. CBP's counts of CF28 requests and seizures are growing, but the source does not quantify the totals.
The players
Customs and Border Protection
The US federal agency responsible for border security and customs enforcement, which is stepping up scrutiny of foreign importers of record and investigating whether DDP arrangements are used to avoid tariffs.
CargoTrans
A freight forwarder that advised US buyers to reconsider delivered duty-paid shipping arrangements amid rising enforcement risk.
The details
CargoTrans says DDP arrangements, under which sellers assume responsibility for import clearance and associated duties, now carry rising compliance risk for US buyers. CBP is increasingly issuing notices of action without first requesting a CF28, and some shipments have been refused, seized, or ordered for re-export.
Timeline
30 October: Revisions to Section 338 tariff coverage for Canadian goods took effect.
9 November: 178 China-related Section 301 product exclusions are scheduled to expire.
9 January: Proposed extension of the suspension of China-linked vessel fees, not yet finalised.
Market Dynamics
The reversal of the post-Liberation Day rush toward delivered duty-paid arrangements signals that importers who adopted DDP to shift tariff exposure to sellers now face heightened CBP scrutiny. CBP's expanding use of ACE customs data analytics is making enforcement decisions faster and less reliant on requests for information.
Importers using DDP arrangements may face refused entry, seizure, or re-export orders if CBP finds the arrangements avoid tariffs, shifting cost and compliance exposure back onto buyers. Businesses should review their clearance responsibilities and the 20-day CF28 response window before shipments arrive.
The takeaway
Importers relying on delivered duty-paid terms should verify who holds clearance responsibility and prepare documentation promptly when CBP requests information. Early review of tariff classifications and exclusion expirations can help avoid costly delays and seizures.
What happens next
Section 301 China-related product exclusions expire on 9 November, and the proposed extension of China-linked vessel fee suspension is slated for 9 January, pending finalisation.
Further reading
Follow related coverage in International Trade for more on how tariff enforcement affects importers.
Source note: This article includes information reported by The Loadstar.
Live Poll
Do you expect the prices of imported goods to rise in your area?
