On June 3, 2026, President Trump issued an Executive Order entitled “Strengthening Customs Enforcement.” The Order signals an acceleration of customs reforms which will increase scrutiny of importer eligibility, foreign importer structures, supply chain disclosures and enforcement actions.
Key Takeaways
Importer-of-Record Eligibility Requirements
The Order directs the Secretary of Homeland Security to revise importer-of-record (IOR) eligibility requirements, demanding identification and affiliation information as well as import data. Foreign IORs will face heightened scrutiny for both informal and formal entries including validation in U.S. Customs and Border Protection (CBP)’s Customs Trade Partnership Against Terrorism and whether they have a U.S. presence.
Supply Chain Disclosure and Certification Obligations Will Expand
Beyond importer eligibility, the Order expands disclosure and certification requirements designed to increase accountability across the supply chain. These requirements will focus on importers’ ability to substantiate compliance and provide detailed information supporting the legality, origin and production history of imported goods.
Enforcement Risk and Penalty Exposure Are Expected to Increase
The Department of Homeland Security is required to take necessary action within the next 90 days that will strengthen enforcement, coupled with a more aggressive use of existing customs authorities and tougher consequences for noncompliance. High on the priority list are forced labor, misclassification, undervaluation and illegal transshipments. Entities not in good standing will no longer have the right to import into the United States.
Actions to Take Now
Given the Order’s aggressive implementation timeline, importers should begin preparing now. At a minimum, companies should evaluate whether their current compliance infrastructure, importer-of-record arrangements and supporting documentation are sufficient to withstand a more demanding enforcement environment.
For questions related to this Order or compliance and enforcement concerns, contact our team or another member of our Supply Chain Industry Group.
