On June 3, 2026, President Trump signed the new Executive Order “Strengthening Customs Enforcement.” This new order from the administration tackles different administrative priorities related to customs: Customs Reform and Combatting Customs Fraud. The order-related fact sheet goes into detail about how the Executive Order addresses these objectives and how this will affect importers moving forward.

What are the new requirements for Importers of Record (IOR) under Customs Reform?

This Order obligates DHS and CBP to strengthen requirements for Importers of Record (IOR) by November 30, 2026. Some of the stronger requirements include:

• Increasing bond requirements and requiring IORs keep a minimum level of “tangible domestic assets, bonds, or both”;

• Requiring an IOR provide additional data if deemed necessary, as it relates to identification information, anticipated import volumes, ownership/beneficial ownership disclosures, business affiliations, domestic assets, etc.;

• Requiring “foreign IORs” be subject to formal entry with heightened requirements, including;
  • Foreign IORs may not rely on continuous bonds for entry except as permitted by CBP (foreign IOR must demonstrate that revenue would be fully protected and compliance with laws and regulations is assured); and
  • Foreign IORs must be validated with CBP’s Customs Trade Partnership Against Terrorism (CTPAT), or the importer must use a CTPAT validated licensed customs broker when filing entries.

• Allowing only “U.S. IORs” to complete informal entries;

• Requiring all IORs be in “good standing” which will be later defined by CBP, but is preliminary defined as an IOR and all affiliates having a history of complying with U.S. customs and trade laws (including payment of required customs liabilities); 

• Any IOR determined by CBP to not be in “good standing” will not be allowed to import goods into the U.S. or participate in activities related to importing goods; and

• Increasing vetting procedures for all individuals and entities seeking to conduct activities related to imported goods.  The list of entities reached beyond the IOR, including affiliates of IOR, customs brokers, custodians of bonded merchandise, and freight forwarders.

Additionally, DHS and CBP must establish disclosure and certification requirements to evaluate imports for duty evasion and noncompliance with supply chain rules. Within 90 days of the Order (or September 1, 2026), steps will be taken to revise all mitigation standards consistent with the policy of this order, such as establishing a “50% minimum penalty floor” that removes some of CBP’s discretion to reduce assessed penalties for importers caught violating customs laws.

DHS must also enhance seizure and disposal procedures of “non-compliant imports” and enhance transparency in customs by taking steps to establish standards and practices that are consistent with the policy of this Order. The department must publish annual transparency reports and propose legislation that strengthens customs enforcement.

Combatting Customs Fraud

The administration cited that “systemic inefficiencies, loopholes, insufficient enforcement mechanisms, and outdated processes” created a need for customs reform that addresses evasion of customs enforcement. The Order directs DHS and CBP to engage in standard rulemaking procedures to create policies that ensure the timely collection of duties and bolster “compliance mechanisms.” 

This Order reemphasizes the Trump administration’s focus on import controls and orders government agencies like DHS and CBP to create more complex regulations for all importers. The fact sheet also references this administration’s focus on “Putting America First in Trade” by referring back to the repeal of the de minimis statutory exception which is set to take place July 1, 2027. Until the official statutory exception is repealed, a previously signed executive order by President Trump suspended the de minimis exception so low-value imports no longer receive duty-free treatment.