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Tougher rules for US imports on DDP put pressure on buyers and suppliers

US companies buying goods on Delivered Duty Paid (DDP) terms have been urged to examine who is responsible for their customs declarations, after US Customs and Border Protection (CBP) introduced new requirements for foreign importers of record (IORs). The interim final rule, published in the Federal Register last week takes effect on 5 January, with new conditions for foreign IORs making both formal and informal entries into the US, as well as additional verification responsibilities for licensed customs brokers. Under the rule, a foreign IOR validated under the Customs-Trade Partnership Against Terrorism (CTPAT) programme can make entries itself, or appoint a licensed customs broker that does not have to be CTPAT-validated. A foreign IOR without CTPAT must designate a broker that is both licensed and CTPAT-validated to make the entry or act as IOR. Where the foreign party is not the owner or purchaser of the goods, the designated broker must act as the importer of record. However, the rule also establishes stricter criteria for determining whether a business qualifies as a US IOR. An individual must be a US citizen or lawful permanent resident, while a company must be organised under US law, located in the country, and at least 51% of its beneficial owners must be US citizens or permanent residents who control the business, or who directly own a significant amount of unencumbered US real estate. Licensed customs brokers will have to verify a client's eligibility before declaring it to be a US IOR. They must request and review supporting records, which could include corporate documents, financial statements, and proof of citizenship or permanent residence. Verification records must then be retained for five years. The development follows CargoTrans's recent tariff webinar, which examined the risks associated with DDP arrangements, noted that in theory an overseas supplier typically arranging import clearance and paying duties and taxes, offered the US buyer a seemingly simpler route to receiving goods. But CargoTrans co-CEO Nunzio De Filippis said the new rule made that convenience harder to achieve, adding: "So that easy button that we spoke about just got harder to press." He advised buyers to establish exactly who is responsible for the import process when their overseas supplier sells on DDP terms. "You have to ask them who is the importer record, who is the customs broker, what does that arrangement look like, and does it meet the new requirements?" he said. "Welcome to the age of strengthening customs enforcement," he added. CBP explained the measures were intended to improve visibility of foreign importers, strengthen accountability, and help ensure duties are collected. The agency highlighted difficulties pursuing unpaid duties and enforcing customs requirements against foreign entities with few US assets. Brokers may request delayed compliance with the new verification requirements before 5 January, but all must be fully compliant by 6 May next year. Comments on the interim final rule are due by 5 January. For US buyers, the update means a DDP quotation alone is no guarantee that the underlying import arrangements meet the new requirements. Buyers should establish who is named as the IOR, which broker is filing the entry, and whether the relevant parties satisfy CBPconditions.

'Multi-node supply chains' are the future, in a 'multi-polar pharma world'

China, India, and the Middle East are all playing their role in shifting the geographical centre of production and innovation, the three regions emerging as particularly important to the global pharmaceutical supply chain Frank van Gelder, secretary general of Pharma.Aero, said a fracturing of the supply chain with a more geographically diffuse network of production, healthcare providers, and clinical centres could create new opportunities for airfreight and specialist logistics providers. "China is no longer only a major source of pharmaceutical ingredients and manufacturing capacity; it is becoming an increasingly important centre for biotechnology, clinical development, and innovative medicines," he told The Loadstar. "India remains essential to generics and manufacturing, while expanding its innovative capabilities; Europe and North America remain central, but innovation and production are becoming more geographically distributed. While Europe and North America would remain important pharma centres, he said the emergence of additional innovation and production hubs was creating what he called a "multi-polar pharmaceutical world". For logistics providers, "that means multi-node supply chains - interconnected manufacturing sites, clinical centres, specialised logistics hubs, and healthcare delivery points, rather than dependence on a few dominant origins and gateways", Mr van Gelder explained. "For air cargo this opens opportunities for new regional gateways and specialised corridors, but it also demands much better network orchestration," he added. However, he cautioned that nodes must be "qualified, connected, interoperable, and economically justified". That meant those considering it needed to be able to distinguish between diversification and "expensive duplication", he said, noting:"More nodes do not automatically mean greater resilience, more tonnage, or better profitability." And he warned that the emergence of regional gateways and specialised corridors would place greater demands on the ability of logistics operators to coordinate, given the increased complexity in these international networks. The requirement for temperature-controlled infrastructure, qualified handling facilities, and reliable connections between different supply chain participants was particularly important as pharmaceutical products become more specialised, he added. Mr van Gelder said: "The most profound change comes with advanced therapies. In autologous cell therapy, a patient's cells can be collected, transported for manufacturing, and returned as a personalised treatment. "Chain of identity, chain of custody, time, temperature, and clinical scheduling become inseparable. A disruption can affect a treatment appointment. Radioligand therapies introduce another set of highly time-sensitive, product-specific constraints," he said. However, Mr van Gelder cautioned against assuming the emergence of new pharmaceutical production centres or growth in innovative medicines would automatically translate into greater airfreight volumes.

Top 20 cargo airports: Fragile but resilient

The 2026 ACI World Airport Traffic Dataset was released in July, revealing which were the top 20 cargo airports in 2025 and considering the dynamics behind the results. Data for 2025 indicates that total global air cargo volumes increased by 3.3% over 2024 volumes, and by 7.4% compared 2019, to 131m tonnes. Earlier in the year, when it published preliminary data for 2025, ACI World described the context for the results as a "resilient but fragile global economy". Global GDP grew by around 3-3.2% in 2025, above expectations but below historical norms, with ongoing risks from trade tensions, protectionism and policy uncertainty affecting aviation demand while geopolitics reshaped traffic flows. Capacity and slot constraints further complicated the picture. However: "Air cargo volumes stabilised near record levels, supported by e-commerce and faster, restructured global supply chains," the association said, noting lower fuel prices, easing inflation, international-led recovery and China's reopening as more positive influences on aviation as a whole, including freight." ACI World observes: "Several of the broader economic and operating conditions that influenced airport [passenger] traffic in 2025 also affected air cargo, though to different degrees. "Global cargo reached a record 131.2m tonnes in 2025, up 3.3%, supported by cross-border e-commerce, high-value and time-sensitive shipments, and changing supply chains. International freight was particularly strong, increasing 4.2%, while domestic freight declined 1.8%. "Geopolitical tensions and disruptions to maritime and air routes have had a more complex effect. They can increase costs and disrupt capacity, but they can also strengthen demand for air cargo when shippers need faster or more reliable alternatives. E-commerce and supply-chain diversification therefore remained important supports to the market." As has been the case in previous years, airfreight traffic was more concentrated amongst the main airports; at 53.1m tonnes, combined air cargo volumes at the top 20 airports represented close to 41% of global air cargo traffic in 2025. Hong Kong tops the charts Hong Kong International Airport (HKIA; 5.1m tonnes, up 2.7% year on year) and Shanghai Pudong (4.1m tonnes, up 8.3%) retained first and second positions respectively. A sad incident occurred in October last year when a cargo aircraft flying into Hong Kong from Dubai veered off the runway on landing, with fatal consequences for two airport staff members whose vehicle was knocked into the sea by the Boeing 747 freighter conversion. The four crew on board the flight, though, were successfully rescued. More positively, Hong Kong's Air-Land Fresh Lane was launched in September 2025, creating a dedicated channel for importing chilled aquatic products, live seafood and fruits from overseas to the Greater Bay Area through HKIA and over the Hong Kong-Zhuhai-Macao Bridge. Live and chilled goods can be delivered to Zhuhai for Mainland's customs clearance and enter the GBA in as quickly as three hours after they arrive at Hong Kong by air, a statement said. New flights last year included Hong Kong Air Cargo services to Glasgow Prestwick and One Air flights from East Midlands to the Asia-Pacific gateway via Liège, as well as an expanded schedule from Dubai-based Etihad Cargo. This year, Air China Cargo and Ethiopian Airlines, too, added freighter flights to Glasgow Prestwick, while Cathay Pacific-owned Air Hong Kong has leased an Airbus A330P2F converted freighter to expand its regional operations. (Cathay Pacific itself placed a firm order for two A350Fs in May.) At Shanghai Pudong, last year brought the relaunch of China Cargo Airlines' Paris-Shanghai freighter service as well as China Eastern's Buenos Aires flights. MyFreighter also initiated flights from the Chinese city to destinations including Amsterdam and Tashkent. This year, Pudong Air Cargo Terminal Co Ltd (PACTL) recently relocated and upgraded its Cross-Border E-Commerce Handling Center at the PACTL West Terminal. The handling area there has been expanded to approximately 4,170 sq m, an increase of 40%; daily handling capacity has doubled. "With expanded space, upgraded equipment and enhanced digital capabilities, the centre is now better equipped to support efficient and reliable cross-border e-commerce operations," PACTL says. Alaska expansion Across the Pacific, Ted Stevens Anchorage International rose from fourth to third place in the ACI World rankings on the back of a 4.2% rise in volumes to 3.9m tonnes. ACI World notes that while the standard ACI definition of air cargo generally excludes transit freight in order to provide a consistent basis for comparison across airports, Anchorage is a specific exception and has reported its total cargo, including transit freight, since the association's database was established back in the early 1990s. "Approximately 70-80% of [Anchorage's] volume is transit freight, reflecting the airport's unique role as a technical and logistics stop between Asia and North America," ACI World acknowledges. Alaska International Airport System (AIAS) director Angie Spear says transit freight represents an important distinction when comparing Anchorage with other airports in the ACI World ranking. She explains: "Unlike airports where most cargo originates or terminates in the local market, a significant portion of the cargo moving through Anchorage continues onward to destinations around the world. "Freight may remain aboard the aircraft during a technical stop or transfer between aircraft before continuing to its final destination. "Anchorage is not simply serving a local cargo market; it functions as an international crossroads where global supply chains connect mid-journey," she emphasises. In fourth and fifth place, Louisville (up from fifth position with 3.4m tonnes handled) and Miami (up from seventh place with 3.1m tonnes) both reported year-on-year growth of over 13% in their volumes, the strongest among the top five. Louisville, where UPS has its global hub, set another record for its busiest year for cargo operations and beat its 2019 total by 21.7%. Miami's throughput, meanwhile, was an impressive 49.5% higher than in 2019; following six years of record-breaking growth, the airport now claims the title of busiest US airport for international freight. On the other hand, Memphis International Airport (the global hub for FedEx) posted a sharp drop in volumes, with cargo down by 20.9% compared to the 2024 figure at just under 3m tonnes. That volume is also 31.3% below the Tennessee airport's 2019 total. UPS's facility at Louisville has overtaken FedEx in Memphis to become the world's busiest express air cargo hub - although FedEx still serves more airports nonstop than any other hub in the world, according to the Global Cargo Hub Review by the Chaddick Institute for Metropolitan Development at DePaul University in Chicago. Noting the "increasing operational complexity" amid which airports must perform, ACI World director general Justin Erbacci says: "These hubs keep people and goods moving, supporting global trade, tourism and economic growth in their communities and regions. "To help keep pace with rising demand, governments must prioritise sustained investment in airports and the broader aviation ecosystem." Investment plans For airports, investment on the freight side of the business can include cargo terminals and warehouses, freighter stands, automated handling and sorting, digital cargo processing systems, customs and screening facilities, improved landside access, and specialised cold chain facilities. According to ACI World: "Governments can support this through enabling policy, efficient customs and border processes, sound planning frameworks, and a predictable regulatory environment that gives investors confidence." Needs vary significantly by airport and market, so investment should address identifiable capacity and efficiency constraints rather than follow a single model. Funding can likewise involve public [or] private-sector investment, including partnerships where appropriate." So, what's the outlook for 2026? Will this year's air cargo results differ markedly from the 2025 figures, for good or ill? And what are the most significant factors behind developments now and in the future? ACI World considers: "The outlook is relatively resilient but more uncertain and geographically uneven. Global air cargo still grew around 3% year over year in the first half of 2026, despite a substantial decline in the Middle East associated with the US-Iran conflict. "E-commerce, high-value shipments and supply-chain restructuring should remain important underlying drivers. However, geopolitical tensions, airspace restrictions, higher fuel and routing costs, trade-policy uncertainty and weaker economic conditions create significant downside risks. "The key point is that these disruptions may affect where cargo moves and through which hubs, rather than necessarily producing an equivalent decline in global demand. For airports, flexibility and the ability to adapt to changing trade corridors are therefore becoming increasingly important."