The White House issued an Executive Order titled “Strengthening Customs Enforcement” on June 3, 2026. The order directs the Department of Homeland Security and U.S. Customs and Border Protection to strengthen customs enforcement, increase importer accountability, expand disclosure requirements, and apply stronger penalties for non-compliance.
While many of the requirements will still need to be implemented through CBP regulations, policies, or guidance, importers should begin preparing now. The order points to a more rigorous enforcement environment, especially for Importers of Record, foreign IORs, low-value shipments, forced labor compliance, valuation, classification, origin, transshipment, and broker due diligence.
Key Areas of Focus
1. Importer of Record eligibility and vetting
The Executive Order directs DHS and CBP to revise IOR eligibility requirements within 180 days. These revisions are expected to include increased bond coverage, minimum levels of tangible domestic assets or bonding, and additional IOR identification data. Importers may also be required to provide information such as anticipated import volumes, year organized, ownership and beneficial ownership details, business affiliations, and domestic asset disclosures.
CBP is also directed to require IORs to remain in “good standing.” Importers that are not in good standing may be restricted from importing into the United States or conducting activities directly related to importation, including designating a customs broker to act on their behalf.
2. New restrictions for foreign Importers of Record
The order places particular emphasis on foreign IORs. DHS is directed to prohibit foreign IORs from filing informal entries under 19 U.S.C. 1498. For formal entries, foreign IORs may face additional requirements, including limits on the use of continuous bonds unless CBP determines revenue is protected and compliance is assured. Foreign IORs may also be required to be CTPAT-validated, where eligible, or use a CTPAT-validated and licensed customs broker to file entries with CBP.
This may have a significant impact on importers using foreign entities as the IOR, particularly for low-value shipments and e-commerce-style import models.
3. Expanded import disclosure and certification requirements
The order directs DHS and CBP to establish heightened disclosure and certification requirements. These may include supply chain compliance certifications, foreign tax and business identifiers, and more detailed product and production information, such as manufacturer product identifiers, model or style numbers, composition, grade, size, or other key specifications.
Within 90 days, DHS is also directed to establish a requirement for importers to submit documentation or information that the foreign exporter was required to provide to the foreign customs administration before export to the United States.
4. Increased enforcement, audits, and penalties
The order calls for stronger enforcement actions, including increased audits, enforcement of liquidated damages claims against bonds, restrictions on in-bond movements, and maximum penalties for brokers that fail to conduct due diligence, repeatedly represent non-compliant clients, or do not respond timely to CBP requests.
The order also directs DHS and the Attorney General to prioritize enforcement related to forced labor, misclassification, undervaluation, and illegal transshipment, including investigations under the Enforce and Protect Act.
Within 90 days, DHS is directed to revise mitigation standards, including establishing a minimum penalty floor of at least 50% of the assessed penalty, absent exceptional circumstances, setting a minimum liquidated damages floor, and eliminating mitigation for repeat offenders.
What Importers Should Do Now
Buckland recommends that importers begin reviewing their customs compliance programs and IOR structure before new requirements are implemented. In particular, importers should:
- Confirm whether their current IOR structure may be considered U.S. or foreign under the Executive Order’s definitions.
- Review bond coverage and prepare for the possibility of increased bond requirements.
- Validate business registration, ownership, beneficial ownership, and domestic asset information.
- Review supply chain documentation for forced labor, origin, valuation, classification, and transshipment risk.
- Ensure product data is complete, consistent, and available at the part, SKU, model, or style level.
- Confirm that foreign suppliers can provide export documentation and production-related information when requested.
- Respond promptly and completely to broker or CBP requests for information.
- Review internal controls for repeat compliance issues, as mitigation may become more limited.
Buckland is monitoring this development and will continue to review CBP guidance as it becomes available. We encourage clients to begin preparing now, particularly if they use a foreign IOR, rely on informal entry processes, have high-volume low-value shipments, or import goods in categories with heightened enforcement risk.
For questions about how this Executive Order may affect your imports, please contact your Buckland representative.