On June 3, 2026, President Trump issued an Executive Order directing the Department of Homeland Security (DHS) and U.S. CBP to implement comprehensive customs enforcement reforms aimed at strengthening importer accountability, combating duty evasion and customs fraud, increasing revenue collection, enhancing supply chain transparency, and protecting national security.
While the Executive Order does not immediately change existing regulations, it establishes phased deadlines for DHS and CBP to develop and implement regulatory and policy changes. The White House indicated that many of these changes will be subject to the standard rulemaking process, providing stakeholders with opportunities to review and comment on proposed regulations before they take effect.
Key provisions include:
Importer of Record (IOR) Requirements: Within 180 days, CBP must revise importer eligibility requirements to require IORs to maintain minimum levels of domestic assets, bonding, or both. Importers will also be required to provide additional information, including ownership and beneficial ownership details, business affiliations, anticipated import volumes, and domestic asset disclosures.
Enhanced Vetting and Disclosure Procedures: CBP will modernize the IOR registry, implement recurring vetting procedures, and establish risk-based importer classifications. Additional importer disclosures may include supply chain information, foreign tax identifiers, global business identifiers, and product-specific details. Within 90 days, CBP must also require submission of certain export-related documentation provided to foreign customs authorities.
Importer Good Standing Requirement: Within 180 days, CBP must establish a “good standing” standard based on compliance history, payment of customs liabilities, and other risk factors. Importers not in good standing could be prohibited from importing goods into the United States.
U.S. vs. Foreign IOR Distinction: The Order establishes stricter criteria for qualifying as a U.S. IOR and directs CBP to prevent the use of shell companies or artificial structures to obtain U.S. importer status. Entities must maintain a principal U.S. business with an actual physical presence and sufficient tangible domestic assets.
Restrictions on Foreign IORs: Foreign IORs would no longer be permitted to file informal entries and would face additional requirements for formal entries, including limitations on the use of continuous bonds and mandatory participation in the CTPAT program, if eligible, or use of a CTPAT-validated customs broker.
Increased Enforcement and Broker Accountability: CBP is directed to aggressively pursue enforcement actions, including liquidated damages and bond claims, increased audits, tighter restrictions on in-bond use, and maximum penalties for customs brokers that fail to exercise due diligence, repeatedly represent noncompliant clients, or fail to cooperate promptly with requests for information by CBP.
Enforcement Priorities: DHS and the Department of Justice will prioritize investigations involving forced labor, undervaluation, misclassification, illegal transshipment, and antidumping and countervailing duty evasion under the Enforce and Protect Act (EAPA).
Penalty Mitigation Changes: Within 90 days, DHS must revise penalty mitigation policies to establish a minimum mitigation floor of at least 50 percent of assessed penalties, create minimum liquidated damages thresholds, and limit mitigation opportunities for repeat offenders.
Additional Measures: The Order directs DHS to expand enforcement authorities, increase bond requirements for high-risk shipments, strengthen seizure and disposal procedures for noncompliant imports, and enhance transparency through annual enforcement reporting and periodic review of confidentiality claims. The Order also requires legislative recommendations for additional customs enforcement reforms within 45 days.
Implementation Timeline: Key actions are phased as follows: within 45 days, legislative recommendations; within 90 days, exporter documentation requirements, penalty mitigation reforms, enhanced seizure and disposal procedures, and transparency measures; within 180 days, importer eligibility reforms, good standing requirements, registry modernization, and expanded vetting; and within one year, a report to the President assessing effectiveness.
This Executive Order represents one of the most significant proposed customs enforcement initiatives in recent years. If implemented as directed, the measures would substantially increase importer vetting, disclosure requirements, bonding obligations, and enforcement exposure. Companies engaged in importing goods into the United States should closely monitor forthcoming CBP rulemaking and Federal Register notices. We will continue to monitor developments and provide updates, as the proposed reforms may require significant compliance and operational adjustments.
For the full text of the Executive Order, please refer to the links below:
Strengthening Customs Enforcement
Fact Sheet: President Donald J. Trump Strengthens Customs Enforcement