New Presidential Executive Order Directing Comprehensive Customs Reform: What Importers and Other U.S. CBP Regulated Parties Need To Know

On June 3, 2026, President Trump signed an Executive Order on "Strengthening Customs Enforcement" to address what the administration characterizes as systemic inefficiencies, loopholes, and insufficient enforcement that have enabled duty evasion and undervaluation of imports. The order explicitly ties customs reform to national security and foreign policy, positioning it as a matter of strategic importance rather than routine regulatory adjustment. This framing suggests the administration may pursue rapid regulatory changes without traditional notice-and-comment procedures, potentially accelerating implementation timelines for affected importers and trade intermediaries.

The order introduces sweeping restrictions on foreign IORs, fundamentally altering import procedures. Foreign entities can no longer file informal entries and must either achieve CTPAT (Customs Trade Partnership Against Terrorism) validation or engage CTPAT-validated customs brokers. All IORs—domestic and foreign—must demonstrate sufficient U.S. assets, bonding, or both; maintain minimum asset thresholds; and satisfy expanded disclosure obligations. Critically, the "good standing" requirement ties IOR operational viability directly to payment of all customs liabilities and admissibility compliance, with violations resulting in import bans or restrictions on import-related activities.

Penalty architecture undergoes a significant structural shift. Within 90 days, CBP mitigation guidelines will establish a 50% minimum penalty floor of assessed penalties absent exceptional circumstances affecting national security, and repeat offenders will receive zero mitigation consideration. Enforcement priorities explicitly emphasize forced labor investigations, misclassification, undervaluation, and illegal transshipment. The order directs enforcement of liquidated damages claims against bonds, audit intensification, and maximum penalties for brokers failing adequate due diligence, repeatedly representing noncompliant clients, or delaying CBP information requests.

Disclosure requirements expand substantially. IORs must now certify compliance with the Countering America's Adversaries Through Sanctions Act and other CBP-determined mandates, disclose foreign tax and global business identifiers, provide detailed supply chain and production method information, and submit any documentation required by foreign customs administrations. Non-compliance triggers both civil and criminal penalties.

For importers and customs brokers, the order necessitates immediate operational adjustments: strengthened compliance programs focused on classification, valuation, and supply chain due diligence; assessment of current bond coverage adequacy; confirmation of U.S. asset levels; and streamlined internal processes for CBP correspondence. Foreign IOR e-commerce providers may require material business model changes. The order particularly targets shell companies and artificial corporate structures designed to qualify as U.S. IORs, signaling aggressive enforcement against circumvention strategies.