What the June 3rd Customs Enforcement Executive Order Means for Your Business
If you're importing goods into the U.S. — or working with anyone who does — this one is worth paying attention to.
On June 3, 2026, President Trump signed an Executive Order called "Strengthening Customs Enforcement," and legal experts are already calling it the most significant overhaul of U.S. Customs and Border Protection (CBP) import rules in over a decade. At Flywheel Sourcing, we want to make sure you understand what's changing and what it means for your supply chain.
Here's a plain-English breakdown of the key provisions and timelines.
1. Higher Standards for Importers of Record — Due by ~November 30, 2026
One of the biggest changes in this EO is a major tightening of who qualifies as an Importer of Record (IOR) — the party legally responsible for a shipment entering the U.S.
Within 180 days, CBP will require all IORs to:
• Hold a minimum level of tangible domestic assets, bonding, or both
• Meet new, higher bond coverage thresholds
• Submit expanded data to CBP — think anticipated import volumes, ownership disclosures, business affiliations, and domestic asset information
• Maintain "good standing" with CBP, which will be assessed based on compliance history, payment of duties, and any enforcement actions against the company or its affiliates
• Undergo enhanced and recurring vetting — and that vetting extends to customs brokers, freight forwarders, and others in the chain
CBP will also be building out a risk-based tiering system for IORs and cleaning up the registry to remove inactive or non-compliant importers.
2. Foreign IORs Face Steeper New Rules — Also Due by November 30, 2026
The EO draws a clear line between U.S.-based IORs and foreign IORs, and the rules for foreign IORs are considerably stricter.
A "foreign IOR" under this order is any individual who isn't a U.S. citizen or lawful permanent resident, or any entity not organized under U.S. law, not located in the U.S., or not controlled by U.S. citizens or LPRs.
For foreign IORs, the new rules include:
• No more filing informal entries (the lower-value, lower-scrutiny entry process)
• For formal entries, continuous bonds will no longer be the default — they'll need individual transaction bonds unless CBP determines revenue is fully protected
• They must be validated through CTPAT (Customs-Trade Partnership Against Terrorism) or file through a CTPAT-validated, licensed customs broker
If you're sourcing from overseas partners who currently serve as their own IOR, this is a conversation worth having sooner rather than later.
3. More Disclosure Required at Entry — Due by September 1, 2026
This one kicks in faster. Within 90 days, importers will need to provide more detailed certifications and disclosures at the time of entry, including:
• Certification of compliance with CAATSA (a federal sanctions law targeting certain foreign adversaries)
• Foreign tax IDs and global business identifiers
• Detailed supply chain and production info — such as the manufacturer's product identifier, model or style number, and key specs like composition, grade, or size
Additionally, within 90 days, DHS will be required to mandate that foreign exporters submit the same documentation to CBP that they already file with their home country's customs authority before shipping to the U.S.
In short: what you know about your supply chain, you'll soon need to be ready to document and certify.
4. Tougher Penalties Across the Board — Due by September 1, 2026
The EO gives CBP significantly more enforcement firepower. Within 90 days, expect:
• Liquidated damages claims against bonds for noncompliance to be actively enforced
• Restrictions on in-bond movement (goods passing through the U.S. without paying duties)
• More frequent audits
• Maximum penalties for customs brokers who cut corners — including those who fail to vet their clients, repeatedly represent noncompliant importers, or don't cooperate with CBP information requests
On the penalty mitigation side, the new rules include:
• A minimum penalty floor of at least 50% of the assessed penalty
• A minimum liquidated damages floor
• Zero mitigation for repeat offenders — if you've been flagged before, you won't be getting a break
The EO also calls for faster seizure and disposal of non-compliant goods, higher bonds for high-risk shipments, and the option for third-party disposal of seized merchandise.
5. New Transparency Requirements — Due by September 1, 2026
CBP will also be required to publish annual enforcement transparency reports and put expiration dates on confidentiality requests. Not a major operational change for most importers, but good context for understanding the overall direction of enforcement.
6. Legislation Recommendations — Due by July 18, 2026
Within 45 days, DHS must submit formal legislative recommendations to the President to further strengthen customs enforcement. This signals that what we're seeing now may just be the beginning — more changes could be coming through Congress.
What We're Watching at Flywheel Sourcing
The deadlines here are aggressive — most of the big changes hit between September and November of this year. Here's what we think sourcing and supply chain teams should be focused on right now:
• Review your IOR setup and bonding levels. The new "good standing" standards will affect who can continue importing without disruption.
• Talk to your overseas partners. If they're currently acting as their own IOR, the new foreign IOR rules are going to directly impact their ability to ship to the U.S. under the current setup.
• Know your supply chain. More detailed documentation requirements are coming. If you don't already have visibility into your manufacturer's production details and compliance records, now is the time to start building that.
• Check in with your customs broker. Brokers are now directly in scope for penalties, which means their due diligence standards are going up — and that's a good thing for compliant importers.
