Chinese New Year 2027: When to Place Orders So Production Isn’t Stuck

Chinese New Year 2027 falls on Saturday 6 February, 11 days earlier than in 2026 when it landed on 17 February. Vietnam’s Tết falls on the same day, so suppliers there follow the same timetable. The official holiday is expected to run from 5 to 12 February, but anyone who has bought from Asian factories knows the real disruption lasts far longer than a week.

6 Feb 2027
Chinese New Year and Vietnam’s Tết fall on the same day
11 days
Earlier than in 2026, when the holiday fell on 17 February
5–12 Feb
Expected official holiday in China
6–8 weeks
Real disruption to production, from early January to mid March

The holiday is a week. The disruption is six to eight.

Output starts dropping two to three weeks before the holiday as workers leave for home and factories stop taking new jobs. After it, many plants take until late February or mid-March to get back to full speed, and some workers don’t come back at all. Plan for a window running from early January to mid-March, not for one week in February.

The earlier date this year squeezes the gap between the holiday sales season and the shutdown. Orders that would normally be placed in December need to be placed now.

Work backwards from your warehouse

Working back from your warehouse
By 15 November
Commit purchase orders for Q1 and spring stock
By 1 December
Sign off samples, secure materials and book freight
Mid December to early January
Your shipping window: finished, inspected and on the water
Mid to late January
Avoid shipping: rates peak and space is scarce
5 to 12 February
Official holiday. Most factories fully closed
Mid February to March
Slow restart. QC-inspect every post-holiday shipment
Free download
Chinese New Year 2027 Production Planner

A 5-page planner with final cut-off dates for the US, Europe and Australia, a week-by-week timeline, a factory closure tracker, LCL and container packing guidance, and checklists.

We’ll email you a copy too. We never share your details. See our privacy policy.

Get four dates from every factory

There is no single closing date that applies everywhere. Ask each supplier, in writing:

  1. The last day they’ll accept new orders.
  2. The last day of production.
  3. The last day goods can be dispatched.
  4. The date they expect to be back at full production.

Treat these as commitments, not estimates, and build them into your purchase orders.

Freight and stock

Aim to ship between mid December and early January. From mid January, freight rates climb steeply and space on vessels is hard to book as everyone rushes to ship before factories close. This year may be gentler: in early November carriers were already discounting Asia to North Europe rates, and forwarders were saying bookings looked lighter than in previous years. Don’t rely on it. Book early anyway.

Hold four to six weeks of extra stock on your best sellers to cover the gap. Running out in March usually costs more than carrying extra stock for a few weeks.

If you import into the US through a foreign company, one more date matters. The new CBP importer of record rule takes effect on 5 January 2027, so most pre-holiday shipments will land under it. Read our guide to the rule before your containers sail.

Talk to us

Bellson Global has managed production through Chinese New Year for more than 20 years. We can confirm closure dates with your factories, schedule inspections before the shutdown and get cargo booked in time. Get in touch or see what we do.

Last updated 7 November 2026. Holiday dates are set by China’s State Council and individual factories, so confirm them directly with each supplier.

Shipping Lead Times from Asia: US West Coast, US East Coast, Europe and Australia

How long it takes to get goods from a factory in Asia to your customers depends far more on where they are going than on where they are made. A container from China reaches Sydney or Los Angeles in about two to three weeks. The same box takes five weeks or more to reach New York or Rotterdam. Here are the current lead times to the four markets most of our customers sell into, and what is changing them.

14–18 days
China to the US West Coast, port to port
28–35 days
China to the US East Coast via the Panama Canal
10–14 days
Extra time to Europe when ships sail around Africa
12–16 days
Fastest direct sailings, Shanghai to Sydney

Port to port is not door to door

Quoted transit times usually cover the ocean voyage only. Add factory pickup, export clearance, waiting for the sailing, unloading, customs and the final truck, and the real lead time is often one to two weeks longer. The chart shows both for shipments from China.

Ocean lead times from China, in days
Port to portDoor to door0102030405060AustraliaSydney, Melbourne, Brisbane12–27 / 22–32US West CoastLos Angeles, Long Beach14–18 / 25–35US East CoastNew York, Savannah, via Panama28–35 / 38–50Europe via SuezRotterdam, Hamburg28–32 / 37–50Europe via the CapeRotterdam, Hamburg42–46 port to port
Sources: Sourcing Pioneer and Dimerco (US), GoFreight and Topway Shipping (Europe), Shanghai Shipping Exchange data via JCtrans, Sino Shipping and Goodhope (Australia). Ranges vary by port, carrier and season.

US West Coast: the fastest way into the US

Direct transpacific services from Shanghai, Ningbo and Shenzhen reach Los Angeles and Long Beach in roughly 14 to 18 days, or 25 to 35 days door to door. From Vietnam allow 20 to 30 days port to port, as many sailings call at a hub first. For warehouses in the Midwest or South, containers usually continue by rail from the West Coast, which can still beat an all-water East Coast routing.

US East Coast: longer, but closer to most customers

All-water services to New York, Savannah and Norfolk through the Panama Canal take about 28 to 35 days from China, or 38 to 50 days door to door. From Vietnam allow 32 to 45 days. The East Coast is the longer sail but puts stock closer to most of the US population, so the right choice depends on where your warehouse and customers are, not just the ocean leg.

Europe and the UK: it depends on the route

Since late 2023 most container lines have sailed around the Cape of Good Hope to avoid the Red Sea, adding 10 to 14 days to every voyage. Lines are now returning to the Suez Canal service by service, which brings Shanghai to Rotterdam back to about a month. Until the return is complete, two sailings to the same port can differ by two weeks, so always ask your forwarder which route each booking takes.

Asia to North Europe and the UK: Suez against the Cape
Via Suez CanalVia Cape of Good HopeShanghai to Rotterdam30–32 days42–46 daysNingbo to Hamburg32–34 days44–48 daysShanghai to Felixstowe31–33 days43–47 days
Port-to-port days. Source: GoFreight, 2026.

Door to door into Germany, the Netherlands or the UK typically runs 37 to 50 days. For urgent, mid-volume cargo, the China–Europe rail service takes about 12 to 14 days by train, at a higher cost per container than sea freight.

Australia: short sailing, strict arrival

Australia is the quickest of the four. Direct sailings from Shanghai to Sydney take about 12 to 16 days, though many regular services run 20 to 27 days, and services that transship through a Southeast Asian hub take longer. Door to door, plan on 22 to 32 days. The extra step is biosecurity: around 8.5% of containers arriving in Sydney from Shanghai need additional inspection, adding 2 to 5 days, so treated timber, clean packaging and correct paperwork matter.

The delays that don’t show in a quote

Transshipment
Calls at hubs such as Singapore or Busan add 3 to 5 days on many Vietnam, India and smaller-port routings.
Chinese New Year
Factories close around 6 February 2027 and space tightens for weeks beforehand.
Customs and inspections
US importer of record checks, EU paperwork and Australian biosecurity can each add days.
Port congestion
Peak season and route changes bunch ships together, stretching every lane.

What to do

  • Plan on door-to-door times for each destination, not the port-to-port figure in a quote.
  • For Europe, confirm whether each sailing goes via Suez or the Cape before you promise delivery dates.
  • Choose the US coast by where your stock needs to be, and compare West Coast plus rail against all-water East Coast.
  • For Australia, check packaging materials and documents against biosecurity rules before goods ship.
  • Build Chinese New Year into every order placed between now and March.
Free download
Chinese New Year 2027 Production Planner

A 5-page planner with final cut-off dates for the US, Europe and Australia, a week-by-week timeline, a factory closure tracker, LCL and container packing guidance, and checklists.

We’ll email you a copy too. We never share your details. See our privacy policy.

Talk to us

Bellson Global manages production and shipping from factories in China, Vietnam, the Philippines and Indonesia to customers in the USA, Canada, Australia, the UK and Europe, and plans every order around real lead times. Get in touch or see what we do.

Sources: GoFreight, Dimerco, JCtrans, Sourcing Pioneer, Topway Shipping, Sino Shipping and Goodhope Freight.

Last updated 7 November 2026. Transit times change with routes, carriers and seasons, so confirm them with your forwarder for each booking.

Which Consumer Products Have Moved Production Out of China?

“Moving production out of China” sounds like one big trend. It isn’t. Some product categories have already left in large numbers, some are moving now, and some are barely moving at all. Which group your product sits in should shape your sourcing plans far more than the headlines do.

44%
Share of US smartphone imports made in India in Q2 2025, up from 13% a year earlier
52%
Share of Nike Brand footwear made in Vietnam in fiscal 2026. China made about 16%
65.9%
Share of US toy imports still coming from China in 2025
4 of 7
Major consumer categories where Vietnam is now the No. 1 source for the US

The clearest way to see it is China’s share of US imports by category. Apparel and beauty products moved years ago. Footwear and furniture have moved a long way. Toys have hardly moved.

China’s share of US imports by category, 2025Toys65.9%Footwear26.1%Furniture20.6%Electronics15.6%Knit apparel14.1%Woven apparel14%Beauty7.9%
Share of US import value by product category. Source: analysis of 2025 US import data by Eightx.

Footwear and apparel: already gone

Footwear and clothing were the first to go, because they’re labour-intensive, margins are thin, and the factories are relatively simple to set up elsewhere. By 2025, Vietnam had become the single largest source of US apparel and footwear imports, and China’s share of US apparel imports had fallen to around 14%.

Nike is the clearest example. In fiscal 2026 its Vietnamese factories made about 52% of Nike Brand footwear and 34% of its apparel, while China’s share of Nike footwear fell to about 16%. Columbia Sportswear reports that about 80% of its footwear now comes from Vietnam.

Indonesia, Bangladesh and Cambodia have taken much of the rest, and India is growing quickly in leather goods and fashion accessories.

Smartphones: the fastest switch

No category has moved faster than smartphones bound for the US, almost entirely because Apple moved iPhone assembly for the US market to India. In the second quarter of 2024, 61% of smartphones imported into the US were assembled in China. A year later that had fallen to 25%, while India’s share jumped from 13% to 44%. The volume of smartphones made in India for the US rose 240% in a year.

Where US smartphone imports were assembledChinaIndia61%13%Q2 202425%44%Q2 2025
Share of US smartphone imports. Source: Canalys.

One caution: most of the components inside those phones still come from China and elsewhere in Asia. India assembles the finished product, which is what customs counts, but the supply chain behind it hasn’t moved nearly as far.

Electronics: assembly moves, the ecosystem stays

Wider consumer electronics are following, mainly to Vietnam. Samsung was the early mover there, and Vietnam’s electronics exports reached roughly $164 billion in 2025. QIMA reported that demand for electronics inspections in Vietnam rose 30% in 2025, a good sign of new production lines starting up.

But China’s share of US electronics imports, at about 15.6% in 2025, understates how much the industry still depends on it. Mexico is now the top source of US electronics imports by value, and most complex components, tooling and engineering know-how remain concentrated in southern China. Final assembly moves easily. The supplier network behind it doesn’t.

Furniture: the low end moves, the high end stays

Vietnam is now the largest source of US furniture imports, with China at about 20.6% in 2025. China’s furniture exports fell 5.9% in 2025, but the decline is concentrated in low-priced upholstered and flat-pack furniture, the categories with the thinnest margins and the most sensitivity to tariffs. High-end, custom and craft-heavy furniture orders have largely stayed in China, where the workshops and materials suppliers are deepest. India is gaining in solid wood furniture.

Toys: still mostly China

Toys are the outlier. About two thirds of US toy imports by value still came from China in 2025, by far the most concentrated major consumer category. Large brands are diversifying: Hasbro said in 2025 that it would move hundreds of US-bound products out of China and shift more of its range to India. But the tooling, plastics, electronics and packaging suppliers that toys depend on are concentrated in China, and that’s hard to replicate.

There’s also less tariff reason to move than there was. Since the new Section 301 forced labour tariffs took effect in July 2026, toys from China and Vietnam pay the same extra 12.5%, so Vietnam no longer has a tariff advantage for most toys.

Where each category stands
Largely moved
  • Footwear (Vietnam, Indonesia)
  • Apparel (Vietnam, Bangladesh, Cambodia)
  • Smartphones for the US (India, Vietnam)
  • Low-end upholstered and flat-pack furniture (Vietnam)
Moving now
  • Consumer electronics assembly (Vietnam)
  • Simple toys and games (Vietnam, India)
  • Leather goods and wooden furniture (India)
  • Home textiles (India, Pakistan)
Still mostly China
  • Toys overall (two thirds of US imports)
  • Complex electronics and components
  • High-end and custom furniture
  • Small appliances and hardware with deep part supply chains
Bellson Global summary based on 2025 US import data, company filings and industry research.

What decides whether a product moves

  • Labour intensity. Products that are mostly hand assembly, like shoes, garments and upholstered furniture, move first.
  • Supply chain depth. Products that need dozens of specialist suppliers within a few hours of the factory, like electronics and electronic toys, stay where those suppliers are.
  • Tariff exposure. Products on the older China Section 301 lists still save 7.5% to 25% by moving. Products that aren’t on those lists save much less today.
  • Order volume. Big brands can fund new factories abroad. Smaller brands usually follow the factories their category has already built elsewhere.

What this means for your products

If you sell footwear, apparel or simple furniture and still buy only from China, your competitors are probably buying cheaper elsewhere. If you sell toys, small appliances or anything with complex electronics, China is still likely to be your best source, and a second supplier elsewhere is mainly insurance. Either way, compare full landed costs product by product rather than following the headlines.

Talk to us

Bellson Global has developed and sourced consumer products across China, Vietnam, India and the rest of Asia for more than 20 years. We can tell you whether your category has a proven alternative supply base, and run the landed cost comparison before you commit. Get in touch or see what we do.

See also: how export shipments from China, Vietnam and the rest of Asia have shifted since 2024.

Sources: Eightx analysis of 2025 US import data by category, Canalys smartphone shipment data, Nike and Columbia Sportswear annual reports, Furniture Discover and QIMA.

Last updated 7 November 2026.

China, Vietnam and the Rest of Asia: How Export Shipments Have Shifted Since 2024

Tariffs were meant to pull production out of China. Three years of shipping data show something more complicated: China is exporting more than ever, Vietnam is growing faster than anyone, and the total volume of goods arriving in the US has barely moved. What changed is where the containers come from.

28.1m TEU
US container imports in 2025, down just 0.4% on 2024
$3.77tn
China’s exports in 2025, up 5.5% to a record
+27.5%
Vietnam’s export growth, January to October 2026
No. 3
India’s rank among sources of US container imports in 2025

China: exporting more, shipping less to the US

China’s exports rose 5.5% in 2025 to $3.77 trillion, and its trade surplus reached a record of almost $1.2 trillion. This year has been stronger again. Exports in the first seven months of 2026 were up 18% on the same period of 2025, and August alone was up 25%.

Shipments to the US followed a very different path. US container imports from China hit an all-time monthly record of 1,022,913 TEUs in July 2024, as importers rushed goods in ahead of expected tariffs. Through 2025 they fell steadily, reaching 705,789 TEUs in December, 31% below that peak. The low point came in April 2026, at 680,778 TEUs.

US container imports from China (TEUs, selected months)1.02mJul 24763kMar 25706kDec 25771kJan 26681kApr 26816kMay 26814kJun 26873kJul 26
Source: Descartes Datamyne monthly Global Shipping Reports. July 2024 was the all-time monthly record.

Since then, volumes have partly recovered. The Supreme Court struck down the IEEPA tariffs in February 2026, and by July China-origin imports had reached 873,129 TEUs, the highest since July 2025. China’s share of all US container imports fell from 38% in 2024 to 34% in 2025, and was back up to 34.8% by July 2026.

China’s share of US container imports202438%202534%July 202634.8%
Source: Descartes Datamyne.

China didn’t lose its exports. It sent more of them to other markets while US tariffs were high, and some of that volume is now coming back.

Vietnam: the biggest winner

Vietnam’s exports rose 17% in 2025 to a record $475 billion, with the US its largest customer at about $153 billion. Its share of US container imports rose by two percentage points.

2026 has been extraordinary. In the first ten months of the year exports grew 27.5% to $499 billion, already more than the whole of 2025. October set a monthly record of $64.7 billion, up 51% on a year earlier.

Vietnam’s total exports (US$ billion)~$406bn2024approx.$475bn2025$499bn2026Jan to Oct only
Sources: Vietnam National Statistics Office; Trading Economics. The 2024 figure is calculated from the reported 17% growth in 2025.

But Vietnam runs on Chinese inputs

Look at the other side of Vietnam’s trade and the picture changes. Its imports grew even faster than its exports, up 37% in the first ten months of 2026 to $511 billion, and China remains its largest trading partner by a wide margin, with two-way trade of around $252 to $256 billion in 2025. Vietnam ran a trade deficit for most of 2026, its first in a decade, as factories brought in machinery and materials.

For importers, that matters in two ways. A product finished in Vietnam may still be full of Chinese components, so a disruption in China can still stop your production. And US customs looks hard at whether goods are genuinely made in Vietnam or only routed through it. Origin is decided by where a product is substantially transformed, not where it ships from.

India, Thailand and Indonesia

The rest of Asia is gaining too, from a smaller base. India climbed to third place among sources of US container imports in 2025. Comparing January 2026 with January 2025, US imports from Thailand rose 36.5%, from Indonesia 18% and from Vietnam 17.8%.

The new US tariff structure may push this further. Since July, India and Indonesia have paid a lower extra tariff than Vietnam or Thailand.

Extra US tariff since 24 July 2026 (Section 301 forced labor)
12.5%
China, plus existing Section 301 duties of 7.5% to 25% on listed goods
12.5%
Vietnam, Thailand, the Philippines, Hong Kong, Singapore
10%
India, Indonesia, Malaysia, Cambodia, Bangladesh
Source: USTR final action, July 2026. Rates stack on top of normal duties.

What this means for sourcing

  • Don’t read “China is over” into the headlines. China is still a third of US container imports and the world’s deepest supply base for most consumer products.
  • Diversify product by product, not country by country. Whether moving production pays depends on whether your product is on the older China Section 301 lists, which still add 7.5% to 25%.
  • Know where your inputs come from, not just where your goods are finished. That’s what customs, tariff rules and forced labour regulations look at.
  • Look beyond Vietnam. India, Indonesia and Malaysia now carry a lower extra US tariff, and their factories are growing quickly.

Talk to us

Bellson Global has sourced and managed production across China, Vietnam and the rest of Asia for more than 20 years. If you’re deciding where to make your next product, we can compare factories and full landed costs country by country. Get in touch or see what we do.

Sources: Descartes Datamyne Global Shipping Reports, Trading Economics, Vietnam News (National Statistics Office data) and China’s General Administration of Customs as reported by AP and Reuters.

Last updated 7 November 2026. Monthly trade figures are revised from time to time, so check the latest releases before relying on a specific number.

High Oil Prices and Peak Season: What Fuel Is Adding to Your Shipping Costs

Oil is back near $100 a barrel. Brent crude traded between about $99 and $102 in the first week of November, roughly $38 higher than a year ago, after a year of conflict in the Middle East and disruption around the Strait of Hormuz. That cost doesn’t stay with oil companies. It moves through ships, trucks and delivery vans into the cost of every order you ship this peak season.

Parcel delivery: fuel surcharges near 30%

This is where most brands will feel it first. FedEx and UPS charge fuel as a percentage of the shipping charge, reset every week from US diesel and jet fuel prices. Reuters put the US diesel price at $6.28 a gallon on 19 October, and ground fuel surcharges have climbed with it. FedEx Ground was 29.25% for the week of 2 November and UPS Ground 30.25%. Air services are higher again, at around 33% to 34%.

Both carriers have also changed the tables that turn diesel prices into surcharges. UPS raised its fuel tables by up to half a percentage point on 2 November, alongside its 2027 rate increase. FedEx followed with a 1.5-point rise at every band from 9 November, taking FedEx Ground to 30.5%. Unlike the diesel price, those table changes won’t reverse when oil falls.

Fuel is also charged on top of other surcharges, such as residential delivery and additional handling, so it compounds. For comparison, when diesel was around $3.70 a gallon a year ago, ground fuel surcharges sat at roughly 22%.

Then the peak surcharges stack on top

Peak demand surcharges are a separate, flat charge per parcel. The highest window runs from 22 November to 26 December at UPS and Amazon Shipping, and from 23 November to 27 December at FedEx, with charges winding down between 14 and 17 January. A standard residential parcel pays $0.75 at UPS and Amazon Shipping and $0.80 at FedEx during those weeks, roughly a quarter more than last year. In January, UPS and FedEx general rate increases of 5.9% arrive as well.

Put together, a ground parcel with a $12 base charge now carries about $3.66 in fuel at 30.5%, against about $2.64 at last year’s rate, plus up to $0.80 in peak surcharge. That’s close to $2 more per parcel. On 2,000 holiday orders, it’s nearly $4,000 that wasn’t in last year’s budget.

Ocean freight: bunker fuel and the lag

Ships burn bunker fuel, and this year bunker prices have at times risen faster than crude. After the Hormuz disruption early in 2026, very low sulphur fuel oil in Singapore peaked at about $1,100 a tonne, against around $540 before the conflict. On 5 November the global average was about $926 a tonne. Prices eased in the first week of November as traders bet on a Middle East peace deal, though traders also expect supply to stay tight toward year end.

Carriers pass fuel costs on through bunker adjustment factors (BAF) and emergency surcharges, usually a few weeks behind the fuel market. Research from the Federal Reserve Bank of St. Louis shows the impact varies widely: older and smaller ships burn much more fuel per container, and longer voyages multiply it. Cargo from Asia to Europe also carries the cost of the EU Emissions Trading System, which covers shipping in full from 2026.

Inland, Maersk is adding an Emergency Intermodal Fuel Surcharge from 16 November on containers moving by rail between US or Canadian ports and inland ramps.

What to do this peak season

  • Model fuel as a weekly variable cost, not a fixed percentage carried over from last year. Check carrier fuel pages every week until January.
  • Get inbound stock moved before the peak windows where you can. Shoulder weeks either side are cheaper.
  • Shrink your packaging. Base rates follow dimensional weight, and the fuel percentage is charged on that base, so a smaller box saves twice.
  • Move anything that isn’t urgent from air to ground. Air fuel surcharges are several points higher.
  • Compare regional carriers and USPS for lighter parcels, while they’re cheaper. USPS introduces its own weekly fuel surcharge in January 2027.
  • Review free-shipping thresholds and delivery prices before Black Friday, using this year’s real cost per parcel.
  • For ocean freight, ask your forwarder whether quotes are all-in, how BAF is calculated, and when it next changes.
  • When you renegotiate carrier contracts for 2027, ask for a discount or cap on fuel surcharges. Over a year, that’s often worth more than a cut to base rates.

Will it ease?

That depends mostly on the Middle East. Oil and bunker prices dipped in early November on hopes of a peace deal, but they’ve swung by $5 to $10 a barrel within single days this autumn. Even if prices fall, parcel fuel surcharges follow diesel with a one to two week delay, and BAF lags further, so any relief will reach your invoices slowly. The higher fuel tables and the January rate increases are here to stay.

Talk to us

Bellson Global designs packaging and plans freight for brands shipping from Asia to the US and Europe, so fuel and surcharge costs are built into decisions before goods leave the factory. Get in touch or see what we do.

Further reading: TransImpact on the FedEx fuel table change and St. Louis Fed research on oil prices and container shipping costs.

Last updated 7 November 2026. Fuel surcharges change weekly, so check current rates on each carrier’s website.

CBP’s New Importer of Record Rule: What Foreign Sellers Must Do Before 5 January 2027

From 5 January 2027, a foreign company can no longer clear goods into the United States under its own name unless it is validated under CBP’s CTPAT programme, or files through a customs broker that is. US Customs and Border Protection published the interim final rule, titled “Heightened Requirements for Foreign Importers of Record”, in the Federal Register on 6 November 2026. That leaves importers less than two months to sort out their filing arrangements, and the rule will catch goods that are already on the water.

Why CBP is doing this

The rule carries out Section 2 of Executive Order 14411, “Strengthening Customs Enforcement”. CBP’s reasoning is simple. When the importer of record sits overseas, its assets and staff are out of reach, so unpaid duties and penalties are hard to collect. CBP says its audits found $1.16 billion in revenue lost through foreign importers of record between January 2020 and August 2026, and it recovered only about $35.7 million of that.

Who counts as a US importer now

For the first time, CBP’s regulations define what a US importer of record is. A company has to pass all three parts of the test:

  1. It is organised under US law.
  2. It is located in the United States.
  3. Either at least 51% of its beneficial owners are US citizens or lawful permanent residents who control the business, or it directly owns a significant amount of unencumbered US real property.

CBP can check. It may ask for evidence of your principal place of business, your physical presence in the US, any property you own, whether the business is adequately capitalised, and whether it is effectively an arm of a foreign manufacturer with no real US presence.

The third condition is the one that will catch small brands. A Delaware or Wyoming LLC with a registered agent address, owned by founders in the UK, Hong Kong or China, can pass the first test and still fail the other two. Being incorporated in the US is no longer enough on its own.

What changes for foreign importers

A company that doesn’t meet the US definition can still import, but it can only enter goods for consumption on its own behalf if it is CTPAT-validated. For almost everyone that route is closed: at present, Canada is the only country whose importers can get CTPAT validation. Everyone else has to file through a customs broker that is itself CTPAT-validated.

There is a further catch. If the foreign party isn’t the owner or purchaser of the goods, the validated broker must act as importer of record for that entry and take on the liability that goes with it. CBP also now requires every importer of record to report its beneficial owners.

Why brokers will get pickier

Brokers carry new duties under the rule. When they take on a client, they must keep a record showing whether that client meets the US importer definition, and CBP has revised its penalty guidelines so it can pursue brokers who get this wrong. Brokers can ask for more time on the verification requirement before 5 January, but must be fully compliant by 6 May 2027.

Expect more paperwork at onboarding, higher fees for foreign clients, and some brokers refusing to act as importer of record at all. CTPAT-validated brokers are a much smaller group than licensed brokers in general, and every foreign seller will be calling them in December.

The timing problem

Ocean freight from China or Vietnam to a US port takes roughly four to six weeks, plus inland rail if your warehouse isn’t on the coast. A container booked in late November will arrive after 5 January. Add the rush before Chinese New Year, when factories push orders out before they close, and many importers will meet the new rule with their biggest shipment of the quarter. Settle your filing route before the goods leave the factory, not when they are sitting at the port.

What to do this month

  1. Work out which side of the line you fall on. Check where your company is organised, whether it has a real US address and staff, and who its beneficial owners are. If you’re unsure, ask a customs attorney or your broker to confirm it in writing.
  2. Call your broker now. Ask whether they are CTPAT-validated, whether they will act as importer of record for you if needed, what that costs, and which documents they want.
  3. Gather your documents: formation papers, ownership and beneficial owner details, proof of your US address and operations, and any property records.
  4. Look at other structures. If you sell to US retailers or distributors, moving to terms where the buyer imports (FOB rather than DDP) puts the importer of record role with a US company. Some US fulfilment partners offer importer of record services, but check carefully who carries the liability.
  5. Check your marketplace setup. Amazon does not act as importer of record for FBA shipments, so sellers need their own arrangement in place.
  6. Comment if the rule hurts your business. Because this is an interim final rule, it takes effect before CBP has heard objections. Comments are due by 5 January 2027, and CBP says it will use them to decide whether to amend, confirm or withdraw the rule.
Free download
Chinese New Year 2027 Production Planner

A 5-page planner with final cut-off dates for the US, Europe and Australia, a week-by-week timeline, a factory closure tracker, LCL and container packing guidance, and checklists.

We’ll email you a copy too. We never share your details. See our privacy policy.

Talk to us before your next shipment

Bellson Global manages production and shipping for brands sourcing from Asia, including the hand-off to customs brokers at the US end. If you’re not sure how this rule affects your next order, get in touch before it leaves the factory, or see what we do.

Further reading: Thompson Hine’s summary of the rule and Flexport’s guide for importers.

Last updated 7 November 2026. This article is general information, not legal advice. Confirm your own position with a licensed customs broker or trade attorney.

Think Beyond China: Smarter Global Sourcing Strategies

In today’s global marketplace, there are a huge range of product sourcing opportunities outside of China that minimize product tariffs. However, selecting the right manufacturing location for your product and business requires a strategic approach to ensure success.

When considering the transfer of product sourcing, manufacturing or selecting an alternative supply base, there are several key factors that should be taken into account:

  1. Tariffs and Duties
  2. Resource Capability
  3. Raw material sourcing
  4. Shipping lead times 
  5. Shipping costs

These variables can differ significantly from one country to another, and are influenced by the type of product being manufactured.  Whether you are sourcing apparel from India or electronics from Taiwan, the success of shifting production from China hinges on choosing an alternative manufacturing base that specializes in your product category.  

Many governments worldwide offer free economic zones where manufacturers  can import raw materials and export products tax-free. By selecting the right country and region for your production , you can minimize tariffs, optimize access to raw materials, and leverage established infrastructure to ensure a stable, efficient supply If you would like to know more about Bellson Global can help with global supply chain optimization contact us: info@bellsonglobal.com