On 3 June 2026, the United States issued the Executive Order "Strengthening Customs Enforcement," directing the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to tighten customs enforcement and to review the rules, policies, and procedures that apply to importers. For foreign companies that ship goods into the United States, this signals a more demanding compliance environment ahead.
What the Executive Order Establishes
The order instructs DHS and CBP to strengthen customs enforcement and to review the regulations, policies, and procedures applicable to importers, customs brokers, supply-chain declarations, penalties, and import compliance processes. While many specifics still depend on future CBP and DHS rulemaking and guidance, the direction is clear: greater scrutiny over who imports into the United States, and how.
Read the full Executive Order on the official White House website
The Central Role of the Importer of Record (IOR)
Importer of Record (IOR)
The person or company legally responsible for correctly declaring imported goods, paying applicable duties and tariffs, and ensuring compliance with U.S. customs and trade laws.
The order indicates that foreign importers acting as IOR may become subject to stricter requirements. Potential measures include:
- Restrictions on informal entries: possible limits on the use of informal entry procedures.
- Additional customs guarantees: larger or additional customs bond requirements.
- Proof of U.S. assets: evidence of assets or operational presence within the United States.
- Beneficial ownership disclosure: identification of ultimate beneficial owners.
- Related-party information: details on affiliated or related companies.
- Supply-chain documentation: records covering the production chain.
- Good standing with CBP: maintaining a compliant record before CBP.
Recommended Preventive Review
Although several details still depend on forthcoming CBP and DHS regulations, guidance, and procedures, we recommend that foreign companies importing into the United States begin a preventive review of their operations now. Key points of attention include:
- Confirming who acts as Importer of Record on U.S. imports;
- Reviewing the current import structure;
- Assessing the sufficiency of the customs bond;
- Verifying presence, assets, or operational structure in the United States;
- Reviewing relationships with licensed customs brokers;
- Checking tariff classification, valuation, and country of origin of products;
- Organizing documentation on suppliers, manufacturers, and the production chain;
- Assessing risks related to transshipment, forced labor, sanctions, origin, and country-of-origin marking;
- Preparing for possible new CBP disclosure and documentation requirements.
"Our team is closely monitoring official guidance as it is published. As more detail emerges on how these measures will be implemented, we will keep our clients informed and prepared."
Disclaimer: This communication is for informational purposes only and does not constitute legal advice. Each import structure must be analyzed individually, considering the specific facts of the company, its products, the supply chain, and the U.S. entry process. If your company imports goods into the United States or acts as Importer of Record, we recommend a preventive review to assess potential impacts and adjustment needs.