Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026, signals a significant shift in how U.S. Customs and Border Protection (CBP) will evaluate importers and enforce customs compliance. For U.S. importers, the message is straightforward: importer-of-record compliance is becoming more important, more transparent, and potentially more costly.
There are several areas that importers should begin preparing for now.
1. Your IOR status will matter more than ever
The Order directs CBP to establish new eligibility requirements for Importers of Record (IORs), including minimum levels of domestic tangible assets, increased bond requirements, and additional disclosures concerning ownership, beneficial ownership, business affiliations, anticipated import volumes, and domestic assets.
CBP is also directed to establish a “good standing” requirement. Importers with significant compliance problems or unpaid customs liabilities could ultimately lose the ability to import or designate a broker to act on their behalf.
2. Foreign IORs face additional requirements
One of the most significant changes is the different treatment of foreign IORs. The Order directs CBP to prohibit foreign IORs from filing informal entries and places additional conditions on foreign IORs making formal entries.
For companies outside the United States that currently act as their own IOR, this deserves immediate attention. Your existing import structure, bond arrangements, and broker relationship may need to be reassessed as CBP implements the Order.
3. Expect more scrutiny of your import data
The Order calls for expanded import disclosures and certifications covering areas such as supply chains, production methods, product identifiers, foreign tax and business identifiers, and compliance with certain federal laws.
In practical terms, importers should make sure their commercial invoices, product databases, classifications, valuations, country-of-origin determinations, and supplier records can withstand greater scrutiny.
4. Enforcement—and penalties—are getting tougher
The Order directs increased audits and enforcement involving misclassification, undervaluation, illegal transshipment, forced labor, and other customs violations. It also calls for changes to penalty mitigation, including a minimum penalty floor of 50% of an assessed penalty in many circumstances and elimination of mitigation for repeat offenders.
That makes proactive compliance increasingly valuable. Finding and correcting an error internally is very different from having CBP identify it first.
What should importers do now?
You don’t necessarily need to change your import program overnight. Many of the Order’s provisions require further action by DHS and CBP before they become operational requirements. However, waiting for the final rules before reviewing your compliance program could leave you scrambling.
Now is a good time to:
- Review your IOR structure and ownership information.
- Confirm your customs bond is appropriate for your current import activity.
- Review classification, valuation, and country-of-origin procedures.
- Examine supplier documentation and supply-chain records.
- Resolve outstanding customs liabilities or compliance issues.
- Review the compliance history of affiliated companies involved in importing.
- Make sure your broker has accurate and complete information about your business and merchandise.
The broader takeaway is that CBP is moving toward a more data-driven, risk-based model of customs enforcement. Importers that maintain accurate records, understand their responsibilities, and address compliance issues proactively will be better positioned as these changes take effect.
Link to the executive order: Strengthening Customs Enforcement – The White House
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