TRADE ADVISORY: Executive Order: Strengthening U.S. Customs Enforcement

Executive Summary

On June 3, 2026, the Administration issued an Executive Order directing DHS and CBP to implement comprehensive reforms to U.S. customs enforcement. The Order is designed to strengthen importer accountability, increase transparency, and close longstanding compliance gaps that have enabled duty evasion and unlawful import practices. These changes will significantly impact importers of record, particularly foreign-based importers, as well as customs brokers and global supply chains.

Key Policy Drivers

The Executive Order identifies systemic weaknesses in current customs enforcement, including undervaluation of imports, incomplete importer identification, lack of ownership transparency, and outdated enforcement mechanisms. According to the Administration, these gaps undermine national security, reduce revenue collection, and disadvantage compliant U.S. businesses.

1. Importer of Record (IOR) Reforms: The Order requires importers to maintain sufficient tangible U.S. assets, bonding, or both, at levels to be determined by CBP. It also mandates increased bond requirements and expanded data filings, including beneficial ownership disclosures, business affiliations, domestic asset information, and anticipated import volumes. All entries must designate an importer of record supported by financial assurances.
2. Restrictions on Foreign Importers: The Order draws a clear distinction between U.S. and foreign importers. Foreign IORs will face heightened compliance requirements and will no longer be allowed to file informal entries. These changes are expected to significantly impact low-value shipments and cross-border e-commerce models.
3. Good Standing Requirement: CBP will establish a 'good standing' requirement for all importers based on compliance history. Importers that fail to meet compliance standards may lose their ability to import goods into the United States.
4. Enhanced Vetting and Compliance: The Order directs CBP to implement enhanced vetting procedures for importers, brokers, and other supply chain actors. Additional disclosure and certification requirements will be introduced to combat duty evasion, forced labor violations, and other noncompliance risks.
5. Increased Enforcement and Penalties: The Order establishes a minimum penalty floor of 50% for customs violations, significantly reducing CBP discretion to mitigate penalties. Enforcement efforts will focus on misclassification, undervaluation, forced labor violations, and other illicit trade practices.
6. Seizure, Disposal, and Transparency: DHS is directed to streamline the seizure and disposal of non-compliant goods and to introduce annual transparency reporting on customs enforcement activities.
7. Implementation Timeline: DHS and CBP are required to revise importer eligibility rules and implement the new framework within 180 days. Additional legislative recommendations are also expected.

Business Impact

Companies importing into the United States will face increased compliance obligations, higher financial assurance requirements, and greater enforcement exposure. Foreign importers will be particularly affected, requiring potential restructuring of importer models and supply chain strategies.

Recommended Actions

Companies should assess importer of record structures, review bonding sufficiency, enhance compliance controls, validate supply chain transparency, and prepare for increased CBP scrutiny. Engagement in upcoming rulemaking processes is strongly recommended.

Disclaimer

This advisory is provided for informational purposes only and reflects our interpretation of the Executive Order titled “Strengthening Customs Enforcement” issued on June 3, 2026, based on publicly available information at the time of publication. This material does not constitute legal advice and should not be relied upon as a substitute for consultation with legal counsel or trade compliance professionals. Companies should assess their specific business activities, import structures, and risk exposure in light of these developments and seek appropriate professional guidance where necessary.

Stay ahead of evolving U.S. customs enforcement requirements. Our trade compliance experts can help you assess your importer of record structure, strengthen compliance controls, and prepare for increased CBP scrutiny. Contact Crane Worldwide Logistics today to schedule a consultation and ensure your supply chain is aligned with the new regulatory landscape