U.S. DDP shipments: what foreign traders should be reviewing now

Questions around DDP shipments into the U.S. are increasing as the customs and tariff environment continues to change. For foreign traders acting as the U.S. Importer of Record, the key issue is not only the additional duty exposure, but whether their current DDP structure, documentation and compliance controls remain appropriate.

Further U.S. Customs enforcement developments are expected around September 1, 2026, so customers should prepare now while avoiding decisions based on requirements that have not yet been formally confirmed.

For foreign businesses trading into the U.S. under DDP terms, this makes the Importer of Record structure particularly important to review. 

Why it matters

Under DDP, foreign sellers can carry significant responsibility for the U.S. import process, particularly where they act as the Importer of Record.

As enforcement expectations develop, businesses may face greater requirements around documentation, importer information, classification, valuation, origin and wider supply-chain compliance.

The important message for customers is that DDP means the foreign seller acts as the U.S. importer of records and remains responsible for customs compliance and delivery to the named destination.

Existing arrangements should therefore be reviewed rather than automatically assumed to remain appropriate.

What traders should do now

Do:

• Confirm who is acting as the Importer of Record and that the associated responsibilities are understood.
• Verify HTSUS classification, country of origin and applicable tariff treatment before entry submission.
• Assess tariff treatment shipment by shipment rather than applying assumptions across all flows.
• Centralize supporting customs and export documentation, particularly where the foreign business is acting as the IOR.
• Review whether the existing DDP and IOR structure remains appropriate for U.S. flows.
• Review contracts and pricing to ensure duties and customs compliance exposure are appropriately considered.
• Maintain supporting shipment documentation.
• Stay closely aligned with the appointed U.S. customs broker.

Avoid:

• Do not assume that using DDP or appointing a customs broker transfers the Importer of Record's compliance responsibilities.
• Do not automatically rely on historic classification, origin or tariff treatment without reviewing the current shipment.
• Do not wait until goods arrive in the U.S. to resolve documentation or IOR questions.
• Do not treat anticipated September 1 measures as final requirements until formal guidance is available.
• Do not restructure an existing DDP model solely on anticipated changes without assessing the customs, commercial and legal implications.

The 90-day milestone falls on September 1, 2026, when further detail on the U.S. enforcement direction is expected. Should you have any questions or concerns, please reach out to your local DSV representative or email us at customs.services@us.dsv.com.