Executive Order on Strengthening Customs Enforcement (June 3, 2026)

On June 3, 2026, the White House issued an Executive Order mandating a comprehensive overhaul of U.S. customs enforcement, with implications for all imports into the United States.  The Order signals a broad tightening of enforcement, emphasizing enhanced importer accountability and vetting, new restrictions on foreign importers, enhanced disclosure obligations, and increased penalties.
While the Executive Order does not immediately impose new regulatory obligations, it directs the U.S. Customs and Border Protection (CBP) and the Department of Homeland Security (DHS) to implement substantial reforms through rulemaking and policy updates in the next 90 to 180 days.

Key Takeaways

Importer Definition

The order outlines the definition of a U.S. Importer of Record (IOR) as an entity that is:

• Organized under U.S. law
• Located in the United States
• Continuously controlled by beneficial owners who are U.S. citizens or lawful permanent residents

Alternatively, a qualifying entity may be one that owns a significant amount of U.S. real estate property.  A U.S. IOR may also be an individual who is a U.S. citizen or lawful resident.

The Order further clarifies that a foreign importer is any importer that does not meet the U.S. IOR definition.

The Importer of Record (IOR) framework is central to the proposed reforms, including:

• Higher financial responsibility requirements (e.g., increased bond amount and/or U.S. assets)
• Expanded data and disclosure obligations (ownership, affiliations, import activity)
• Creation of a “good standing” requirement, under which non-compliant importers risk losing import privileges

Additionally, CBP is expected to update the IOR registry by removing inactive IORs; confirming active IORs are compliant with all applicable regulations and disclosures; and establishing a risk-based tiers for IORs based on compliance history, enforcement actions, and audit results, and other relevant factors.

Increased Scrutiny for Foreign Importers

• Foreign Importers may not file Informal Entries
• Foreign Importers may file Formal Entries if conditions are met, including:
• Meeting enhanced bonding requirements, demonstrating that revenue will be fully protected and compliance with applicable laws and regulations will be ensured
• Participation in CBP’s Customs Trade Partnership Against Terrorism (CTPAT), if deemed eligible, or use of a CTPAT-validated and licensed customs broker to file entries
• Must meet all other importer eligibility requirements to import to the U.S.

Expanded Supply Chain Transparency Requirements

The Order mandates enhanced certification and reporting requirements related to:

• Ownership and beneficial ownership
• Supply chain sourcing and compliance
• Adherence to applicable trade laws (e.g., forced labor, valuation, and classification requirements)
• Within 90 days, CBP will require export-related documentation or information provided to foreign customs authorities upon exportation

More Aggressive Enforcement and Penalties

The order signals a material shift in enforcement posture, including:

• Establishment of a minimum penalty floor (generally 50%), limiting mitigation discretion within 90 days
• Increased audits, investigations, and seizure of non-compliant goods
• Enforcing bond claims
• Heightened focus on key areas such as undervaluation, transshipment, and duty evasion

Additional Enforcement Framework Updates

Additional directives include:

• Enhanced importer vetting and registry management
• Increased transparency in CBP reporting
• Potential regulation proposals to further expand enforcement authority

If you have any questions, please contact your C.H. Robinson representative.

Resources

Executive Order: Strengthening Customs Enforcement – The White House

Fact Sheet: President Donald J. Trump Strengthens Customs Enforcement – The White House

White House issues new executive order to strengthen customs enforcement, protecting U.S. consumers and businesses | U.S. Customs and Border Protection