A new era of customs enforcement: What the June 2026 US Executive Order means for importers

Key learnings from the June 2026 US Executive Order:

• Baseline overhaul for IORs: The June 2026 Executive Order requires all Importers of Record (IORs) to meet new minimum thresholds for domestic assets, data disclosures, and bond coverage within 180 days.
• Strict “good standing” mandate: Importers must maintain a formal compliance record with CBP; any link to illicit substances triggers a total US import ban.
• Crackdown on foreign IORs: Entities lacking a physical US presence are banned from filing informal entries and must use CTPAT-validated operations or brokers for formal continuous bonds.
• Heightened supply chain disclosures: Expect strict new documentation demands, with enforcement heavily prioritising forced labor, undervaluation, misclassification, and illegal transshipment.
• Harsher penalties and expedited seizures: The order sets a strict 50% minimum penalty floor for violations, eliminates leniency for repeat offenders, and fast-tracks the disposal of non-compliant goods within 90 days.

On June 3 2026, the White House issued a sweeping new Executive Order titled Strengthening Customs Enforcement. Designed to close regulatory loopholes, increase supply chain transparency, and aggressively target non-compliance, this order directs US  Customs and Border Protection (CBP) to significantly overhaul its vetting, bonding, and security frameworks.

These updates represent a substantial shift in the regulatory landscape for Importers of Record (IORs). Understanding these incoming changes will help businesses to protect their supply chains from disruptions and severe penalties.

The primary updates roll out over a staggered 90-to-180-day timeline and will fundamentally change how merchandise enters the United States. 

Here are the key requirements you need to know:

Stricter rules and “Good Standing” for all importers

Within 180 days, all IORs must meet new baseline requirements to operate. CBP will mandate minimum thresholds for tangible domestic assets and/or increased bond coverage. Additionally, the registration process will require deep-dive data disclosures, including anticipated import volumes, beneficial ownership, business affiliations, and domestic asset details.

Crucially, CBP will introduce a strict, unprecedented ‘good standing’ mandate. While CBP has always penalised non-compliance, IORs must now formally maintain this status based on their entire compliance history and corporate affiliations. If an entity is found to be linked to the importation of illicit substances (such as fentanyl, nitazene, or precursor chemicals), they will lose their good standing and face a total ban on importing into the United States.

Heavy restrictions on foreign IORs

The Executive Order draws a hard line between US and foreign IORs, introducing strict limitations for entities without a physical US presence or US-controlled beneficial ownership.

Foreign IORs will be banned from filing informal entries, which are typically used for low-value shipments. For formal entries, foreign IORs will generally be restricted from using continuous bonds unless they are validated under the Customs Trade Partnership Against Terrorism (CTPAT) program or utilise a CTPAT-validated, licensed customs broker.

What this means for foreign IORs without a physical US presence:

• No more “informal entries” for low-value goods: You can no longer use simplified, low-value clearance processes (like Section 321 or traditional informal entries); all of your shipments must now go through full, formal commercial entry processes:

“…the Secretary shall promptly issue, amend, modify, or rescind any relevant regulation, policy, or guidance to prohibit a foreign IOR from filing informal entryunder regulations promulgated pursuant to 19 U.S.C. 1498.”

• Higher up-front costs or slower clearance: Because you are generally banned from using continuous bonds, you will have to buy “single transaction bonds” for every individual shipment, unless you meet strict CTPAT security requirements:

“…the Secretary shall promptly issue, amend, modify, or rescind any relevant regulation, policy, or guidance to require for formal entry under 19 U.S.C. 1484 that a foreign IOR: (1) may not rely on a continuous bond to meet the bond requirements for entry…”

• Urgent pressure to join CTPAT: To maintain cost-effective operations, you will be forced to either get your own operations validated under the CTPAT program or exclusively hire a CTPAT-validated US customs broker to handle your filings.

“…the Secretary shall promptly issue, amend, modify, or rescind any relevant regulation, policy, or guidance to require for formal entry under 19 U.S.C. 1484 that a foreign IOR: … (2) be validated in CBP’s Customs Trade Partnership Against Terrorism (CTPAT), if determined by CBP to be eligible, or use a CTPAT validated and licensed customs brokerto file entries with CBP.”

Heightened disclosures and target enforcement areas

Prepare for a significant increase in required supply chain documentation. Importers will soon need to:

• Certify compliance with anti-smuggling laws (18 U.S.C. 545) and the Countering America’s Adversaries through Sanctions Act (CAATSA).
• Provide detailed product specifications, including composition, grade, size, and specific manufacturer identifiers.
• Submit copies of the exact export documentation filed with foreign customs authorities prior to exporting to the US (taking effect within 90 days).
• Disclose specific foreign tax and global business identifiers.

While CBP will be monitoring overall compliance, the Department of Homeland Security and the Department of Justice are being directed to heavily prioritise enforcement around four key areas: forced labor, misclassification, undervaluation, and illegal transshipment.

Elevated vetting, broker accountability, and strict penalty floors

CBP is mandating recurrent vetting for all parties involved in importation, including IORs, freight forwarders, and customs brokers.

For violations, the order establishes a minimum penalty floor of at least 50% of the assessed penalty and completely eliminates penalty mitigation for repeat offenders. Furthermore, CBP is expediting the seizure and disposal of non-compliant goods, streamlining this process to take effect within the next 90 days.

Accountability does not just stop at the importer; the order establishes maximum penalties for customs brokers who fail to conduct proper due diligence, repeatedly represent noncompliant clients, or fail to cooperate with CBP.

How to prepare for these changes

As federal agencies finalise the exact regulatory rules and bonding thresholds over the coming weeks, now is the time to review your import setup – especially if you work with foreign-based importers, rely on informal entries, or have exposure to the priority enforcement areas.

Navigating evolving trade regulations can be complex, but proactive preparation is the best defense. If you have questions around how these changes may impact your business, get in touch today.