Trump Signs Executive Order Overhauling U.S. Customs Enforcement

President Donald Trump signed an executive order on June 3, 2026 directing a comprehensive overhaul of U.S. customs enforcement, targeting what the administration describes as systemic loopholes that allow foreign importers to evade duties, undervalue goods, and avoid compliance with federal trade law. The order, titled “Strengthening Customs Enforcement,” instructs the Department of Homeland Security and U.S. Customs and Border Protection to implement a broad set of reforms over the next 90 to 180 days, with significant consequences for foreign sellers, customs brokers, and any business that imports goods into the United States.

What Triggered the Order

The White House framed the executive order as a long-overdue correction to structural weaknesses in the U.S. customs system. The order cites specific practices the administration says have undermined federal law, including undervaluing imports to reduce duty liability, withholding information about importers of record, and using complex arrangements to avoid paying duties altogether. As CBP Commissioner Rodney Scott stated upon signing, “Importing into the U.S. has for too long been treated as a right and not a privilege.”

The order points to forced labor violations, misclassification, illegal transshipment, and intellectual property breaches as additional areas where the current system has fallen short. It also specifically targets fentanyl and other illicit substance imports as a compliance priority.

Key Changes for Importers of Record

The order's most substantive provisions center on tightening who qualifies as an importer of record and what obligations that designation carries. Within 180 days, DHS must revise IOR eligibility rules to require the following changes. The new rules will include:

• Higher bond coverage minimums and requirements for IORs to maintain tangible domestic assets at all times
• Beneficial ownership disclosures, business affiliation disclosures, and domestic asset disclosures filed with CBP
• Anticipated import volume reporting and enhanced background vetting, including recurrent vetting for all entities involved in importing

A new “good standing” requirement will apply to all IORs. CBP will define good standing based on compliance history, enforcement actions, and audit results. IORs found to have imported fentanyl, nitazene, or other illicit substances will not qualify for good standing and will be barred from importing into the United States or designating a customs broker to act as IOR on their behalf. The IOR registry will be cleaned up within the same 180-day window, removing inactive registrants and creating risk-based compliance tiers.

Foreign IORs Face Tighter Restrictions

The order draws a sharp distinction between U.S.-based and foreign importers of record, and that distinction carries major practical consequences for cross-border e-commerce platforms. Under the directive, only U.S.-based importers would be permitted to file informal entry transactions, while all importers would be subject to the new good standing requirement.

Foreign IORs filing formal entries will face two additional requirements. First, they will no longer be permitted to rely on continuous bonds to meet bond requirements, except in limited circumstances where CBP determines revenue is fully protected. Second, they must either be validated through CBP's Customs Trade Partnership Against Terrorism program or use a CTPAT-validated licensed customs broker to file entries.

The Coalition for a Prosperous America, which has long pushed for IOR reform, called the order “the most significant overhaul of importer accountability in a generation,” arguing it directly addresses the imbalance between foreign sellers with no meaningful U.S. presence and domestic producers who must comply with the full weight of U.S. customs law.

Penalties Are Getting Harder

The order establishes a 50% minimum penalty floor, meaning CBP will no longer have discretion to reduce assessed penalties below half the original amount except in exceptional circumstances that materially affect national security. Mitigation for repeat offenders is eliminated entirely.

Additional enforcement measures include stricter enforcement of liquidated damages claims against bonds, restrictions on in-bond utilization, an increase in audits, and maximum penalties for customs brokers who fail to conduct due diligence, repeatedly represent non-compliant clients, or fail to cooperate with CBP information requests. The order also directs DHS to expedite the seizure and disposal of non-compliant imports within 90 days, including by authorizing third-party disposal and reducing regulatory burdens on voluntary abandonment.

What Sellers and Importers Need to Do Now

The reforms will be implemented through the federal rulemaking process, giving businesses a defined window to adjust. However, as Buckland Customs advised in its analysis of the order, importers should begin preparing now rather than waiting for final regulations to appear.

For e-commerce businesses that import goods directly, the immediate priorities are confirming your IOR status and compliance history with your customs broker, reviewing your bonding arrangements to assess whether they will meet the new minimums, and auditing your supply chain documentation for product classification, valuation accuracy, and country-of-origin data. For foreign sellers using third-party logistics providers or customs brokers as their IOR, confirming those partners hold CTPAT validation is now a basic due diligence requirement.

The order also instructs DHS to submit legislative recommendations to the President within 45 days, signaling that regulatory changes alone may not be the end of this process. A one-year effectiveness report is required, which means CBP will be measuring and publishing its enforcement outcomes, giving the administration a documented basis for further tightening if the 180-day reforms do not produce the compliance improvements it is targeting.