Major Changes for Foreign Importers of Record

On June 3, 2026, the White House announced a new executive order titled “Strengthening Customs Enforcement”, directing the Department of Homeland Security and U.S. Customs and Border Protection to pursue comprehensive customs reform. The order is focused on strengthening enforcement of U.S. customs laws, improving importer accountability, and reducing opportunities for duty evasion and supply chain noncompliance.

While the executive order does not immediately change every import process overnight, it signals a more enforcement-focused customs environment. Many of the operational details are expected to move through DHS and CBP rulemaking, which means affected parties should have time to understand and adjust to final requirements once they are issued.

Why the Executive Order Matters

According to the White House fact sheet, the administration views customs enforcement as both an economic and national security issue. The order is designed to address what the administration describes as “inefficiencies, loopholes, insufficient enforcement mechanisms, and outdated processes” within the customs system. 

For businesses that import goods into the U.S., the larger message is clear: importer responsibility, accurate documentation, and compliance history may become even more important in the years ahead.

Key Provisions in the Executive Order

Stronger Importer of Record Requirements

One of the most significant areas of focus is the importer of record, often referred to as the IOR. The importer of record is the party legally responsible for ensuring that goods are properly entered into the United States, duties are paid, and applicable laws and regulations are followed. It is important to note that as a freight forwarding company, Sheltered International cannot act as an IOR.

The executive order directs DHS and CBP to strengthen several requirements for importers of record. These requirements, subject to change, include:

  • Minimum domestic tangible assets or bonds
  • Higher bond coverage
  • Expanded disclosure of ownership and beneficial ownership, business affiliations, domestic assets, and expected import volumes, and any other data CBP deems necessary

Customs bonds and importer accountability are central to CBP’s ability to collect duties and enforce penalties when violations occur.

Heightened Scrutiny for Foreign Importers of Record

The order also specifically directs DHS and CBP to consider heightened requirements for foreign importers of record for formal entries. In practical terms, this could affect overseas sellers, foreign manufacturers, e-commerce businesses, and companies that import into the United States without a strong domestic presence.

For companies using foreign IOR structures, this is an area to watch closely. 

Informal Entry Could Become More Limited

Another notable provision directs DHS and CBP to authorize only U.S. importers of record to file informal entries. Informal entry is commonly associated with lower-value shipments and simplified entry processes.

This does not mean every informal entry process changes immediately. However, it does suggest that CBP may take a closer look at who is filing these entries and whether the importer of record has a sufficient U.S. presence. Importers that depend heavily on lower-value shipment models should pay attention to future guidance.

Good Standing and Expanded Vetting

The order also directs DHS and CBP to impose a “good standing” requirement on all importers of record and increase vetting procedures for individuals and entities directly involved in importing goods.

While the definition of “good standing” is yet to be shared, the concept points toward more review of importer reliability. CBP may consider factors such as registration accuracy, compliance history, bonding, documentation practices, and whether the importer has demonstrated a pattern of responsible conduct.

Penalty Exposure Could Increase

One of the most notable enforcement provisions in the order is the direction to establish a 50% minimum penalty floor. 

If implemented, this could make penalty mitigation less flexible in certain cases. For importers, that means errors involving classification, valuation, origin, entry documentation, or duty payment could carry greater financial consequences.

Documentation mistakes and inconsistent entry practices may create significant risk if enforcement standards become more stringent.

Seizure and Disposal of Non-Compliant Imports

Beyond financial penalties, the executive order also directs DHS to “enhance seizure and disposal procedures for non-compliant imports”. This includes authorizing third-party disposal. While the specific procedures will depend on agency action, the order emphasizes “eliminating regulatory burdens” for these actions.

What This Means for Importers, Brokers, and Forwarders

For importers, the executive order reinforces the importance of having a clear, compliant import structure. Businesses should know who is acting as importer of record, how goods are being entered, and whether the documentation supporting those entries is accurate and complete.

For companies with international supply chains, the order is also a reminder that customs compliance is not limited to the moment goods arrive at the port. Compliance begins with sourcing, supplier selection, product classification, valuation, and shipment planning.

Although the executive order signals a stronger enforcement environment, many of the reforms are not expected to take effect immediately. In fact, many deadlines relate to the Secretary of Homeland Security pursuing revisions to current laws. Here is a brief outline of important dates to keep in mind:

  • 45 Days (July 18): Submit recommendations for legislation
  • 90 Days (September 1): Require submission of documentation from foreign exporters, establish minimum penalty floor of at least 50 percent, and enhance seizure and disposal of non-compliant imports
    • 180 Days (November 30): Revise importer eligibility regulations, require all IORs to maintain good standing
  • 1 Year (June 3, 2027): Submit a report on effectiveness of revisions

Stay in Control with Sheltered International

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