ACCEPTABLE QUALITY LIMIT (AQL) FOR PRODUCT INSPECTIONS

There is a moment in every first import when the seller realises that the container is not the problem. The paperwork is.

Your goods are made, inspected and loaded. The freight is booked. And then a document is missing, or the wrong entity is named on the customs entry, or Amazon refuses the delivery, and thirty thousand dollars of inventory sits in a bonded warehouse accruing storage while somebody works out whose name should have been on a form.

This guide covers the leg that the sourcing guides skip: what happens between the factory gate and the Amazon fulfillment center, and what decides whether shipping to Amazon FBA from China ends in a clean check-in or in demurrage. Two rules changed in 2026, and both of them move responsibility upstream, towards the factory, and towards you.

The rule that changed in June 2026

On 3 June 2026, Executive Order 14411, "Strengthening Customs Enforcement", directed US Customs and Border Protection to overhaul the rules governing who may act as importer of record. It specifically targets foreign importers of record and the shell structures used to create them, requires new bonding and domestic asset standards, and sets a minimum penalty floor. Most of it must be implemented within 90 to 180 days of that date. If your Chinese supplier or forwarder is arranging DDP delivery to Amazon, somebody is acting as importer of record on your behalf, and that arrangement is now under direct scrutiny.

The Journey: Five Legs, and the Three That Slip

A shipment from a Chinese factory to an Amazon fulfillment center has five legs. Importers plan the one in the middle and are ambushed by the other four.

Leg	What happens	Who controls it
1. Factory to port	Collection, export documentation, export customs clearance in China	Your supplier, or your forwarder
2. Ocean or air transit	The leg everybody quotes and the only one anybody plans	The carrier
3. US customs entry	The entry is filed, duties are paid, the goods are released or held	The importer of record. See the next section.
4. Port to Amazon	Deconsolidation, drayage, delivery appointment	Your forwarder
5. Amazon check-in	The shipment is received, or it is not	Amazon

Legs 1, 3 and 5 are the ones that slip, and none of them is a freight problem. Leg 1 slips because a document from the factory is wrong. Leg 3 slips because the customs entry names the wrong party or the bond is insufficient. Leg 5 slips because the delivery appointment is not available when your container is, or because the units do not meet Amazon's requirements at check-in.

Who Is the Importer of Record? (Amazon Is Not)

This is the single most consequential question of the whole shipment, and most first-time importers never ask it.

The importer of record is the party legally responsible to US Customs for the entry: for declaring the goods correctly, for the tariff classification, for paying the duties, and for the accuracy of every statement made on the entry. If the classification is wrong, the importer of record pays. If the goods are non-compliant, the importer of record answers for it.

Amazon is not, and will not be, your importer of record. Amazon does not act as importer of record, consignee or declarant for your inventory. It will not pay duties on your behalf and it refuses shipments that arrive requiring it to do so. Your goods must clear customs before Amazon ever sees them.

So somebody has to be the importer of record. In practice there are three arrangements, and they are not equivalent.

Arrangement	Who is the importer of record	The risk
You, as a US company	Your own US entity	The cleanest. You carry the liability, and you can see it.
You, as a foreign company	Your non-US entity, acting as a foreign importer of record	Legal under current rules, with a resident agent and a customs bond. This is what Executive Order 14411 targets.
Your supplier or forwarder, under DDP	Somebody else, whose name you may not know	You have outsourced a legal liability to an entity you have not vetted. See section 8.

What Changed in June 2026: Executive Order 14411

On 3 June 2026, the President signed Executive Order 14411, "Strengthening Customs Enforcement". It is a directive to the Department of Homeland Security and to CBP rather than a rule in itself, and it sets deadlines: 45 days for legislative recommendations, 90 days for several requirements, 180 days for the overhaul of importer eligibility. That places implementation between September and the end of November 2026.

It creates a legal category, the foreign importer of record, and treats it very differently from a US one.

How the order defines a US importer of record

This is the definition that will surprise most sellers. To qualify as a US importer of record, an entity must be organised under US law, be located in the United States, and have controlling beneficial owners who are US citizens or lawful permanent residents. Failing that, it must own a significant amount of US real property.

Your US company may not be a US importer of record

A great many sellers have registered a US entity believing it settles the question. Under this order it may not. A US-registered company whose controlling beneficial owner is not a US citizen or permanent resident falls into the **foreign** importer of record category. The order is explicit about why. It directs that guidance on what "located in the United States" means must prioritise preventing entities from using shell companies, sham transactions or artificial corporate structuring to qualify as a US importer of record. At a minimum, the entity must have its principal place of business in the United States, a physical presence where significant business activity is conducted, and sufficient tangible assets in the United States.

What a foreign importer of record now faces

Requirement	Detail
Informal entry prohibited	A foreign importer of record may not file informal entry. The route commonly used for lower-value shipments closes.
No continuous bond	On formal entry, a foreign importer of record may not rely on a continuous bond, except where CBP is satisfied that revenue is fully protected.
CTPAT	A foreign importer of record must be validated in CTPAT, or must use a CTPAT-validated licensed customs broker to file its entries.
Bonding and domestic assets	Every importer of record must maintain a minimum level of tangible domestic assets, bonding, or both, and CBP must raise minimum bond coverage.
Disclosure	Anticipated import volumes, year organised, ownership and beneficial ownership, business affiliations, domestic assets.
Good standing	Defined by CBP on compliance history and payment record. An importer not in good standing may not import at all, and may not designate a customs broker to act as importer of record on its behalf.
Recurrent vetting	Applies to foreign importers of record, their affiliates, customs brokers, bonded custodians and freight forwarders.
Penalties	A minimum penalty floor of not less than 50 per cent of the assessed penalty, absent exceptional circumstances materially affecting national security. Plus a minimum liquidated damages floor, and mitigation eliminated for repeat offenders.
Seizure	Expedited seizure and disposal of non-compliant imports, with increased bond requirements for high-risk shipments.

The two clauses that reach into your factory

Section 3(a) requires heightened disclosure of the imported good's supply chain and production methods, including the manufacturer's product identifier, such as the model or style number, and key specifications such as composition, grade and size. That information is not in your office. It is on the production line.

Section 3(b) goes further. Within 90 days, CBP must establish a requirement mandating the submission of any documentation or information that the foreign exporter was required to submit to its own customs administration before exporting to the United States.

Read that again. What your Chinese supplier declared to Chinese customs is to be handed to US customs. If the two declarations do not say the same thing, you are the one who signed the entry.

The pattern, twice in one year

In July 2026, CPSC eFiling made importers file certificate data, including the date and place of manufacture, electronically with US Customs at the moment of entry. In June 2026, this order requires the documentation your Chinese exporter filed with Chinese customs to be handed over as well, along with the manufacturer's own product identifiers and specifications. Both rules do the same thing. **They pull information out of the factory and make you answerable for it.** The paperwork now starts in Asia and the liability ends with you. If you have never verified what your supplier declares, this is the year that stops being a theoretical problem.

See our CPSIA compliance guide for the eFiling half of this picture.

The Documents, and Which Ones Come from Your Factory

A US customs entry runs on documents, and most of them are produced by somebody standing in a factory in Guangdong.

Document	Produced by	What goes wrong
Commercial invoice	Your supplier	Undervaluation, vague descriptions, wrong currency. Undervaluation is your liability, not theirs.
Packing list	Your supplier	Quantities that do not match the invoice or the container
Bill of lading	Your forwarder	Wrong consignee, wrong notify party
HTS classification	You, or your broker	The wrong code means the wrong duty. The importer of record pays the difference and the penalty.
Certificate of origin	Your supplier	Origin claims that do not survive scrutiny
Importer Security Filing (ISF)	You or your broker, before the vessel sails	Filed late, and the penalty is automatic
Compliance certificates (CPC, test reports)	You, from laboratory data	Now filed electronically with Customs at entry, since July 2026. See our guide to product testing for Amazon FBA.
Chinese export documentation	Your supplier	New. Under Executive Order 14411, CBP must require this within 90 days.

Look at the left column again. Five of these eight are produced by, or depend on, your supplier. You sign for all of them.

An importer who has never asked to see what their factory declares to Chinese customs is about to be asked to hand that declaration to US Customs.

Ocean, Air or Express: Choosing the Mode

The mode decision is usually made on price, and it should be made on cash flow. Ocean freight ties up your capital for weeks. Air freight costs several times more and frees it.

The trap is not the mode. It is the number you were quoted.

Port to port is not the whole journey, and this is where every first import goes wrong

A forwarder quotes you a transit time. That number is almost always the vessel's sailing time, port to port. It does not include collection from the factory, export clearance in China, waiting for a sailing, US customs clearance, drayage, or the Amazon delivery appointment. How wide is the gap? One freight guide published this year gives the China to US West Coast lane as fourteen to thirty-four days, a twenty-day spread inside a single article. Flexport, which actually measures it, put the same lane at thirty-seven days in the week to 23 March 2026, and 53.3 days to the East Coast. Flexport's number is higher than the top of that range, and it still stops at the port gate.

Flexport publishes an Ocean Timeliness Indicator, updated weekly from its own shipping operations. It is the most honest public number available, and its methodology is the reason: it measures from the cargo ready date at the exporter's factory to the container's departure from the destination port. In other words it counts the waiting, the loading and the port dwell that a sailing-time quote leaves out.

What it does not count is the leg that comes next: the drayage to the fulfillment center and the Amazon delivery appointment. Those go on top.

So the sequence for planning is: Flexport's indicator for the ocean portion, plus US customs clearance, plus drayage, plus the Amazon appointment. Check the live index rather than any figure quoted in an article, including this one.

Two structural facts that do not move:

• The East Coast costs you two to three extra weeks. Flexport has consistently measured a gap of roughly sixteen to twenty days between the two coasts.
• LCL is slower than FCL, because your cargo waits at origin to be consolidated with other people's, and is broken apart again at destination.

Amazon Global Logistics: Amazon Sells the Freight, Not the Liability

Amazon sells freight. Amazon Global Logistics is a door-to-door ocean and air programme that moves inventory from China and Vietnam directly into Amazon fulfillment centers and Amazon Warehousing and Distribution facilities, booked, paid and tracked inside Seller Central. Its pricing covers pickup at origin, export declaration, the ocean or air leg, destination customs clearance, and delivery to the warehouse.

It is genuinely convenient, and it is worth pricing against a forwarder. But read what Amazon asks you for when you set it up.

Amazon's own words, on its own signup page

To open an Amazon Global Logistics account, Amazon tells you to set up a payment method, **provide your importer of record details**, and upload the required documents. Amazon is selling you the freight and asking you, in the same breath, to name the party that will carry the legal liability at the border. That party is not Amazon. Even when Amazon collects your cargo at the factory, clears it through customs and delivers it to its own warehouse, **you are still the importer of record.**

The distinction is worth stating precisely, because it is where sellers get it wrong.

What Amazon Global Logistics does	What it does not do
Handles the customs process: the brokerage, the entry filing, the clearance	Take the customs liability. You remain the importer of record.
Quotes freight and clearance in one price	Cover import duties and taxes. Those are still yours.
Delivers into the fulfillment center	Inspect your product. Receiving is a six-sided look at the outside of each unit and a check that it matches the listing title. Nobody turns it on.
Collects at your supplier's door	Verify what your supplier declared, or what is actually in the cartons

AGL removes the work of finding a forwarder and a broker. It removes none of the responsibility. If the declared value is wrong, if the classification is wrong, if the origin claim does not hold, the name on the entry is yours.

Delivering to an Amazon Fulfillment Center

The last leg has its own way of failing.

Requirement	Consequence of getting it wrong
A delivery appointment, booked through Amazon's carrier system	No appointment, no unload. Your container waits, and demurrage runs.
Shipment created in Seller Central, with matching labels and box IDs	A mismatch between the container and the plan stops the check-in
Units fully prepped and labelled	Since January 2026, Amazon no longer preps units at any price
Cartons within Amazon's published limits	Refused at the door

The appointment is the leg nobody plans. It depends on the fulfillment center, on current intake volumes, and on the season, and it can add days or weeks that appear on no freight quote. Build it into the schedule as a leg in its own right, not as a rounding error.

For everything Amazon checks at receiving, see our Amazon FBA requirements guide.

DDP from China: The Shortcut That Transfers Your Risk Without Removing It

Almost every Chinese supplier will offer to ship DDP, delivered duty paid, straight to Amazon. It sounds like the problem has been solved. One price, one contact, goods appear in the warehouse.

Understand what you have actually bought. Under DDP, somebody else arranges the customs entry, and somebody else's name goes on it as importer of record. That somebody is often an entity you have never seen, selected by your supplier, operating on a bond you know nothing about.

Three things follow.

You do not control the declaration. The value declared, the classification used, the origin claimed: none of it passes across your desk. If it is wrong, the goods are still yours, and a CBP enquiry will still find you.

You do not build a customs record. Executive Order 14411 requires CBP to establish a good standing standard based on compliance history. If every entry is made in somebody else's name, you have no history. You are a new importer forever.

The arrangement itself is now the target. The order explicitly restricts foreign importers of record and the shell structures behind them, and requires bonding and domestic asset standards. Low-cost DDP-to-Amazon services out of China are precisely the model that scrutiny is aimed at.

DDP is not fraud, and plenty of it is legitimate. But it is not the absence of risk. It is risk you have handed to somebody whose incentive is to get the container in, not to keep you compliant. Ask who your importer of record is. If your supplier cannot tell you, that is the answer.

Where the Inspection Fits

Everything on this page happens after the container is sealed, and almost none of it can be fixed once it is.

A pre-shipment inspection is the last moment at which the goods, the packaging, the labelling and the documents are all in the same place, in Asia, with somebody able to look at them.

Put the two checkpoints side by side. Amazon looks at six sides of your unit and confirms the title matches. An inspection opens it, tests whether it works, and samples the lot against ISO 2859-1. Only one of those is a quality control, and it happens before the container is sealed.

What an inspection catches at the factory	What it costs if it reaches customs or Amazon instead
Quantities that do not match the packing list	A customs discrepancy on the entry
Labelling and markings that do not match the shipment plan	A refused delivery at the fulfillment center
Units that do not meet Amazon's prep requirements	Since January 2026, Amazon does not fix these at any price
Product defects, found by opening the unit, testing its function, and sampling the lot against ISO 2859-1	A customer review. Amazon's check-in looks at six sides of the unit and confirms the title matches. It never turns the product on.
Documents that do not match the goods	An importer of record signing for a declaration that is not true

That last line is the one that has changed. Until 2026, a document that did not quite match the goods was a paperwork irritation. Under CPSC eFiling and Executive Order 14411, it is an entry filed with US Customs in your name.

AQF runs two forms of FBA check, and the difference matters for this page. The enhanced FBA inspection covers the goods themselves: quantity, workmanship, functionality, on-site tests, and the delivery packaging. The pure FBA verification is the pre-despatch check on the shipment itself: the delivery labels, the bill of lading, and the shipping cartons' dimensions, weight and contents. The document risks described above are where the second of these earns its place. See our pre-shipment inspection and our FBA inspection service, and, if you are still choosing your fulfilment model, our comparison of FBA and FBM.

Frequently Asked Questions

Can I ship directly from my factory in China to an Amazon fulfillment center?

Yes, and it is common, but the goods must clear US customs before Amazon receives them, and the delivery must have an appointment booked through Amazon's carrier system. Amazon does not act as importer of record, will not pay duties on your behalf, and refuses shipments that arrive requiring it to do so. In practice this means a customs broker, a customs bond and an importer of record are in place before the container sails, not after it arrives.

Is Amazon the importer of record for my FBA shipment?

No, and this holds even when Amazon is the one moving your freight. Amazon's own Global Logistics signup instructs sellers to provide their importer of record details, which tells you plainly where the liability sits: Amazon will handle the customs process, the brokerage and the clearance, but it does not take the customs liability, and its freight quotes exclude import duties and taxes. Somebody must be named on the customs entry: your US entity, your non-US entity acting as a foreign importer of record, or a third party under a DDP arrangement. Whoever is named carries legal responsibility to US Customs for the declared value, the tariff classification, the origin and the duties.

What is Executive Order 14411 and does it affect Amazon sellers importing from China?

Executive Order 14411, "Strengthening Customs Enforcement", was signed on 3 June 2026 and directs the Department of Homeland Security and US Customs and Border Protection to overhaul the rules governing importers of record. It specifically restricts foreign importers of record and the shell structures used to create them, requires a designated importer of record backed by a bond or sufficient domestic assets, increases minimum bond coverage, expands the disclosures importers must make, establishes a CBP good standing standard based on compliance history, and sets a minimum penalty floor of not less than 50 per cent of the assessed penalty. Most of it must be implemented within 90 to 180 days of that date. It affects any Amazon seller importing from China who relies on a non-US entity, a supplier or a freight forwarder to act as importer of record, which includes most DDP arrangements.

Is DDP shipping from China to Amazon safe?

DDP is legitimate, but it is not the absence of risk. Under DDP, somebody else arranges the customs entry and somebody else is named as importer of record, often an entity chosen by your supplier that you have never vetted. You do not control the declared value, the classification or the origin claim, yet the goods are yours and a customs enquiry will find you. You also build no customs compliance record of your own, which matters now that CBP is establishing a good standing standard based on import history. Executive Order 14411 explicitly targets foreign importers of record and shell structures, which is the model many low-cost DDP-to-Amazon services rely on. Ask who your importer of record is. If your supplier cannot tell you, that is the answer.

How long does shipping from China to Amazon FBA take?

Longer than the number you were quoted, because most freight quotes are port-to-port sailing times and exclude collection from the factory, Chinese export clearance, waiting for a sailing, US customs clearance, drayage and the Amazon delivery appointment. The published figures show how little a single number is worth: one freight guide gives the China to US West Coast lane as fourteen to thirty-four days, a twenty-day spread inside one article, while Flexport, which measures the lane from the cargo ready date at the exporter's factory to the container's departure from the destination port, put it at thirty-seven days in the week to 23 March 2026, and 53.3 days to the East Coast. Note that even Flexport's figure stops at the port gate: the drayage to the fulfillment center and the Amazon delivery appointment come on top of it. Plan against the full sequence, treat the Amazon appointment as a leg in its own right, and check Flexport's live index rather than trusting any figure quoted in an article.

What documents do I need to import from China to Amazon FBA?

A commercial invoice, a packing list, a bill of lading, a correct tariff classification, a certificate of origin where applicable, an Importer Security Filing made before the vessel sails, and any compliance certificates your product requires, which since July 2026 must be filed electronically with Customs at the time of entry. Executive Order 14411 adds another: within 90 days of 3 June 2026, CBP must require submission of the documentation your Chinese exporter had to file with its own customs administration before exporting. Most of these documents are produced by your supplier, and all of them are your legal responsibility.

Does Amazon check my products when they arrive at the fulfillment center?

Amazon's receiving process is a check-in rather than a quality inspection. Associates scan the shipping label, open the carton, set aside anything that still needs prep, perform a six-sided visual check of each unit for damage, and verify that the product matches the listing title. The unit is then stowed. What does not happen is a functional test, a comparison against your approved sample or specification, or any sampling plan against an AQL. Nobody switches the product on. A unit therefore passes Amazon's check-in with a failing solder joint, the wrong voltage, a cracked internal component or a substituted material, because none of that is visible from six sides. Amazon is verifying that it can store and ship your unit, not that your unit works.

What is a customs bond and do I need one?

A customs bond is a financial guarantee to US Customs that duties, taxes and penalties will be paid. It is required to make entry into the United States, and it is obtained through a surety, usually arranged by your customs broker. Executive Order 14411 directs CBP to increase minimum bond coverage and to require each importer of record to hold a bond, sufficient domestic assets, or both. If you are importing through a third party's bond under a DDP arrangement, you do not have a bond of your own, and you are not building a record with CBP.

Can a non-US company be the importer of record?

Under the rules as they currently stand, yes: a non-resident company can act as importer of record if it has a resident agent authorised to accept service of process, and a customs bond in place. Executive Order 14411 directs CBP to restrict this route, redefining such entities as foreign importers of record, tightening eligibility, and requiring bonding or domestic assets. The implementing rules are expected within 90 to 180 days of 3 June 2026. Anyone currently importing into the US through a non-US entity should be planning for that route to narrow rather than assuming it will stay open.