On June 3, 2026, the President signed an executive order titled Strengthening Customs Enforcement, directing the Secretary of Homeland Security to reform how the United States regulates importers of record (IORs). The order signals a meaningful shift in federal customs policy, and U.S. businesses that import goods—or rely on foreign partners to do so—should expect increased compliance obligations, sharper penalties, and closer scrutiny of their filings and supply chain relationships.
A central feature of the order is the heightened qualification standard for IORs. Foreign importers of record are now prohibited from filing informal entries, narrowing a channel that some overseas sellers have historically relied upon to move lower-value shipments into the U.S. market. For formal entries, the order requires either validation under the Customs Trade Partnership Against Terrorism (CTPAT) program or the use of a licensed customs broker. Companies that have informally relied on foreign affiliates or third-party sellers as the IOR should evaluate whether those arrangements remain viable, and whether broker engagement or CTPAT participation is now necessary to maintain continuity.
The order also strengthens the substantive obligations attached to each entry. Importers will face enhanced disclosure and certification requirements, meaning more detailed and verifiable information must accompany filings. Minimum penalties for noncompliance are increased, and the government is authorized to pursue expedited disposal of goods that fail to meet applicable requirements. Taken together, these measures raise both the cost of error and the speed at which consequences may be imposed, leaving less room to correct deficiencies after the fact.
Finally, the order requires the Department of Homeland Security to implement annual enforcement reporting. This reporting mandate suggests that customs enforcement will remain a sustained federal priority rather than a one-time policy adjustment, and that data-driven targeting of noncompliant importers is likely to intensify over time.
Companies should consider reviewing their IOR designations, broker relationships, CTPAT status, internal compliance procedures, and contractual allocations of customs risk with foreign suppliers. Documentation practices and certification workflows may also warrant updating in light of the new standards.
This article provides general information only and is not legal advice. Clients with specific questions about how the executive order may affect their import operations should seek tailored counsel from qualified legal advisors.