On June 3, 2026, President Trump signed an executive order titled “Strengthening Customs Enforcement” that rewrites the rules for every Importer of Record bringing goods into the United States. This is not a tariff. It is a structural overhaul of who is allowed to act as an IOR, what financial backing they must hold, how they are vetted, and what happens to importers who rely on weak or non-compliant IOR arrangements. The order directs US Customs and Border Protection to implement minimum asset and bond thresholds for all IORs, recurrent vetting of every IOR and their affiliates, a new “good standing” requirement, and significant restrictions on foreign IORs. Most of these changes must be in place within 180 days, which sets a hard deadline at the start of December 2026.
For any company importing into the United States, the practical question is simple: will your current IOR arrangement survive the new CBP vetting process, or are you about to discover that the entity you rely on to clear your goods does not meet the new standard? The customs enforcement executive order 2026 draws a hard line between IORs with genuine US presence, assets, and compliance history and the paper IOR arrangements that have operated on the margins for years. This guide breaks down exactly what the order requires, the three separate deadlines it sets, the new definition that separates a compliant US IOR from a restricted foreign IOR, and the specific actions every importer should take now to protect their supply chain before December 2026.
What the Customs Enforcement Executive Order 2026 Actually Requires
The order is built on a clear premise stated in its own text: effective customs enforcement ensures that importers of record are correctly identified and accountable for the duties they owe. The administration’s position is that systemic loopholes, insufficient enforcement, and outdated processes have allowed some importers to undervalue goods, withhold information about who the real IOR is, and avoid paying duties through various arrangements. The order responds by tightening the requirements on every IOR, with the heaviest new obligations falling on foreign IORs and on any arrangement designed to obscure who is actually responsible for a shipment.
“Effective customs enforcement prevents the importation of unlawful and dangerous goods; ensures importers of record are correctly identified and accountable for duties owed; and guarantees compliance with numerous Federal laws.”
Strengthening Customs Enforcement, The White House, June 3, 2026
The core changes fall into five areas, each carrying its own compliance weight:
- Minimum assets and bonding: Every IOR will be required to maintain a minimum level of tangible domestic assets, bonding, or both, as determined by CBP. The minimum required bond coverage for an IOR will increase
- Expanded data at registration: IORs must provide CBP with additional data including anticipated import volumes, year the entity was organised, ownership and beneficial ownership disclosures, business affiliation disclosures, and domestic asset disclosures
- Good standing requirement: All IORs must maintain “good standing” with CBP, defined by the IOR’s and its affiliates’ history of compliance and payment of customs liabilities. IORs not in good standing will not be allowed to import or to designate a customs broker to act as IOR on their behalf
- Recurrent vetting: CBP will establish enhanced vetting procedures, including recurrent vetting, for all individuals and entities involved in importation, including foreign IORs, affiliates of IORs, customs brokers, custodians of bonded merchandise, and freight forwarders
- Risk-based IOR registry: CBP will update the IOR registry, remove inactive IORs, confirm active IORs are compliant, and create risk-based tiers based on compliance history, enforcement actions, and audit results
The Three Deadlines That Matter: 45, 90, and 180 Days
Most coverage of this order treats it as a single December 2026 deadline. The reality is more complex and more urgent. The order sets three separate implementation windows, and the earliest obligations begin to bite in the summer of 2026, not December.
| Deadline | Date | What Must Be in Place | Impact on Importers |
|---|---|---|---|
| 45 days | Mid-July 2026 | Legislative recommendations submitted to the President | Signals the scope of permanent statutory change ahead |
| 90 days | Early September 2026 | Foreign exporter documentation requirement; 50% minimum penalty floor; streamlined seizure and disposal; transparency measures | Cost of any compliance error rises sharply; origin-to-import documentation must align |
| 180 days | Early December 2026 | IOR asset and bond minimums; foreign IOR informal entry ban; foreign IOR formal entry restrictions; good standing requirement; updated registry; recurrent vetting | Your current IOR arrangement must meet the new standard or your goods may not clear |
| 1 year | June 2027 | Effectiveness report to the President | Sets the direction for further tightening and possible legislation |
The 90-day window is the one most importers overlook. By early September 2026, the penalty mitigation standards change. The order sets a minimum penalty floor of 50 percent of the assessed penalty, absent exceptional circumstances that materially impact national security. It also eliminates penalty mitigation for repeat offenders entirely. An importer who today might negotiate a penalty down significantly will, from September, face a floor of half the assessed amount with no relief available if they have a prior violation. The cost of a compliance error rises sharply before the headline IOR changes even take effect in December.
The New Line Between a US IOR and a Foreign IOR
The most consequential part of the order is its new definition of what counts as a US IOR versus a foreign IOR. This distinction determines which entities can continue filing entries normally and which face severe new restrictions. The definitions are precise, and they are designed to close the loopholes that paper IOR arrangements have used for years.
What Qualifies as a US IOR
Under the order, a US IOR is a United States citizen or lawful permanent resident, or an entity organised under US law, located in the United States, with controlling beneficial owners who are US citizens or lawful permanent residents at all times. Alternatively, an entity qualifies if it owns a significant amount of real property in the United States, as determined by the Secretary. The order then goes further and defines what “located in the United States” actually means, specifically to prevent gaming. At a minimum, the entity must have its principal place of business in the United States, a physical presence where significant business activity is conducted in the United States, and sufficient tangible assets located in the United States, taking into account the scale of the company’s overall operations.
The Anti-Shell-Company Provision
The order explicitly instructs the Secretary to provide guidance on “located in the United States” that prioritises preventing entities from using shell companies, sham transactions, or artificial corporate or organisational structuring to qualify as a US IOR. This is the provision that ends a common workaround. A foreign company that set up a thin US shell with no real assets, no genuine business activity, and no domestic operations specifically to file as a US IOR will not meet this standard. The order names this practice directly and closes it.
The New Restrictions on Foreign IORs
A foreign IOR, defined as any IOR that does not meet the US IOR test, faces two specific new restrictions that change how it can operate:
- No informal entry: Foreign IORs will be prohibited from filing informal entry, the simplified process generally used for low-value shipments. The order reasons that foreign IORs handling high volumes of low-value goods are less familiar with US trade law and face lower penalties, making informal entry a risk to enforcement
- Restricted formal entry: For formal entry, a foreign IOR may not rely on a continuous bond except where CBP is satisfied that revenue is fully protected, and the foreign IOR must either be validated in CBP’s Customs Trade Partnership Against Terrorism (CTPAT) program or use a CTPAT-validated and licensed customs broker to file entries
The combined effect is that a foreign company can no longer rely on lightweight IOR arrangements to move goods into the US market. It must either meet the substantive US IOR test, work through a CTPAT-validated broker, or partner with a compliant US IOR that holds genuine domestic assets and bonding. For companies that have been importing through a foreign IOR or a thinly capitalised intermediary, this is the moment that arrangement stops working.
Is your current IOR exposed to the new foreign entity restrictions? Carra Globe’s Importer of Record services provide the verified US presence, domestic assets, and compliance history the new CBP standard demands.
Why This Hits Importers Who Thought Their Compliance Was Settled
The companies most exposed by this order are not the ones knowingly cutting corners. They are the importers who outsourced their IOR function years ago, were told it was handled, and have not examined the arrangement since. From the programmes we manage, three situations come up repeatedly, and all three are now exposed.
The Importer Using a Foreign IOR Without Realising the Exposure
A company importing IT hardware, medical devices, or industrial equipment into the US may have an IOR arrangement set up through an overseas supplier or a foreign logistics intermediary. Under the old rules this worked. Under the new rules, if that IOR is a foreign IOR, it cannot file informal entry at all and faces continuous-bond restrictions plus a CTPAT requirement on formal entry. The goods that moved smoothly last quarter may face a blocked or delayed entry once the December rules take effect. The importer did nothing wrong. The rules changed underneath the arrangement.
The Company Relying on a Thinly Capitalised IOR
Some IOR providers operate with minimal domestic assets and minimal bonding, pricing aggressively precisely because they carry little financial backing. The new minimum asset and bond thresholds are designed to remove exactly these providers from the market. An importer relying on a low-cost IOR with no tangible US assets may find that provider unable to meet the new CBP minimums, which means the importer needs a new IOR before December or faces an interruption to its ability to clear goods. The CBP risk-based tiering will also flag low-compliance-history IORs, and importing through a low-tier IOR may itself attract additional scrutiny.
The Business Whose IOR Has a Compliance History It Cannot See
The good standing requirement ties an importer’s ability to clear goods to the compliance history of the IOR and its affiliates. If your IOR or a company affiliated with it has a history of customs violations, unpaid liabilities, or enforcement actions, that history can now affect your ability to import through them. Most importers have never audited the compliance history of their IOR provider. Under the good standing rule, that history becomes directly relevant to whether your goods clear.
The Heightened Disclosure and Penalty Regime
Beyond the IOR rules, the order tightens disclosure and penalties for every importer regardless of how their IOR is structured. By September 2026, importers face new certification requirements including certifying compliance with critical supply chain laws such as the Countering America’s Adversaries through Sanctions Act, disclosing certain foreign tax and global business identifiers, and providing detailed supply chain and production information such as the manufacturer’s product identifier, model or style number, and key specifications like composition, grade, or size.
The order also requires, within 90 days, that importers be prepared to submit any documentation the foreign exporter was required to provide to the foreign customs administration before exporting to the United States. This is a significant new evidentiary burden. CBP will be able to compare what was declared on export from the origin country against what is declared on import into the US, and discrepancies become an enforcement trigger. For companies managing complex supply chains, the documentation chain from origin export to US import must now align precisely.
On penalties, the order is deliberately severe. It directs CBP to enforce liquidated damages claims against bonds for noncompliance, restrict in-bond utilisation, increase audits, and impose maximum penalties on brokers who fail to conduct due diligence or repeatedly represent noncompliant clients. The 50% minimum penalty floor and the elimination of mitigation for repeat offenders mean the financial consequence of any compliance failure rises materially from September 2026. For the broader CBP audit environment that this order intensifies, see our analysis of the CBP customs audit landscape in 2026.
Five Actions Every US Importer Should Take Before December 2026
- Confirm whether your IOR qualifies as a US IOR under the new definition. Ask your IOR provider directly: are you organised under US law, located in the United States with a genuine principal place of business and physical operations here, and do you hold sufficient tangible domestic assets? If your IOR is a foreign entity or a thin US shell, you need to understand that now. The distinction between a US IOR and a foreign IOR determines whether your goods clear normally from December. Our IOR services operate as a genuine US-present importer of record with the domestic assets, bonding, and compliance infrastructure the new rules require
- Request written confirmation of your IOR’s bonding level and asset position. The new minimum bond and asset thresholds will be set by CBP within 180 days. A provider that cannot or will not confirm its bonding and domestic asset position in writing is a provider you cannot verify against the coming standard. Build this confirmation into your vendor review now, before the thresholds are published and the market scrambles to comply simultaneously
- Audit your IOR’s compliance history and good standing. Under the new good standing requirement, your ability to import is tied to the compliance record of your IOR and its affiliates. Ask whether your IOR or any affiliated company has open enforcement actions, unpaid customs liabilities, or a history of violations. An IOR that lands in a low CBP risk tier can expose your shipments to additional scrutiny even when your own goods are fully compliant
- Align your origin-to-import documentation chain before the September 90-day deadline. This is the date most importers will miss. Well before the December IOR overhaul, the 90-day requirement to produce foreign export documentation takes effect, meaning the data declared when goods leave the origin country must match the data declared on US import. Review your commercial invoices, product identifiers, valuations, and origin declarations across the full chain. Any gap between the export filing and the import filing is now an enforcement trigger. Use our landed cost guide to confirm your valuation methodology is documented and defensible
- Build a contingency IOR relationship now, not in November. If there is any doubt about whether your current IOR survives the new rules, the time to establish a compliant alternative is during the implementation window, not after a shipment is blocked at the border in December. The companies that wait until the deadline will be competing for compliant IOR capacity at the same moment. The companies that act now will have a verified, US-present, properly bonded IOR in place before the rules take effect
How the Customs Enforcement Executive Order 2026 Connects to the Wider Enforcement Direction
This order does not stand alone. It is the structural counterpart to the enforcement trends already reshaping US imports in 2026: the suspension of de minimis treatment that ended duty-free low-value imports, the intensified CBP focus on valuation and origin fraud, and the rising audit activity targeting misclassification and illegal transshipment. The order explicitly prioritises enforcement against forced labour imports, misclassification, undervaluation, and illegal transshipment under the Enforce and Protect Act. Companies that have shifted sourcing away from China to alternative origins should pay particular attention, because the same order that tightens IOR rules also sharpens the tools CBP uses to challenge country-of-origin claims. See our guide to the IOR and compliance gaps in the shift to Vietnam, India and Mexico for how origin scrutiny intersects with these new requirements.
The direction is unmistakable. The US is moving toward an import environment where the identity, financial backing, and compliance history of the importer of record are central to whether goods are allowed in. The era of the lightweight, low-visibility IOR arrangement is ending. The importers who treat this as the structural shift it is, and who secure a genuinely compliant IOR before the deadlines, will keep their supply chains moving while others scramble.
Frequently Asked Questions
When do the new IOR rules under the customs enforcement executive order take effect?
The core IOR rules, including new bond and asset minimums, foreign IOR restrictions, the good standing requirement, and recurrent vetting, must be implemented by CBP within 180 days of June 3, 2026, which sets a deadline at the start of December 2026. Penalty and disclosure changes take effect earlier, within 90 days, around early September 2026.
The order sets staggered deadlines rather than a single date. Legislative recommendations are due within 45 days, disclosure and penalty changes within 90 days, the main IOR overhaul within 180 days, and an effectiveness report within one year. Importers should treat September 2026 as the first hard date, not December.
What is the difference between a US IOR and a foreign IOR under the new order?
A US IOR is a US citizen, lawful permanent resident, or an entity organised under US law that is genuinely located in the United States with a principal place of business, physical operations, and sufficient tangible domestic assets. A foreign IOR is any IOR that does not meet this test, and it faces a ban on informal entry plus continuous-bond and CTPAT restrictions on formal entry.
The order specifically targets shell companies and artificial structures used to fake US IOR status. A thin US entity with no real assets or business activity will not qualify. The distinction determines whether an IOR can continue operating normally or faces the new foreign IOR restrictions.
Can a foreign company still import into the US after this order?
Yes, but not through the lightweight arrangements many have used. A foreign company must either meet the substantive US IOR test, use a CTPAT-validated and licensed customs broker for formal entry, or partner with a compliant US IOR that holds genuine domestic assets and bonding. Foreign IORs are barred from informal entry entirely.
The most reliable path for a foreign company is to work with a properly established US-present IOR that already meets the asset, bonding, and good standing requirements. This removes the foreign IOR restrictions from the equation because the entity of record is a compliant US IOR.
What does the “good standing” requirement mean for my imports?
Good standing ties your ability to import to the compliance history of your IOR and its affiliates. CBP will define good standing based on history of compliance with customs laws and payment of customs liabilities. An IOR not in good standing cannot import or designate a broker to act as IOR on its behalf.
This means the compliance record of your IOR provider directly affects whether your goods clear. If your IOR or an affiliated company has unpaid liabilities or enforcement history, that can now block your imports. Auditing your IOR’s standing is no longer optional due diligence; it is operationally essential.
How do the new penalty rules change the cost of a compliance error?
From around September 2026, the order establishes a minimum penalty floor of not less than 50 percent of the assessed penalty, absent exceptional national security circumstances, and eliminates mitigation entirely for repeat offenders. The ability to negotiate penalties down significantly is sharply reduced.
Combined with increased audits, enforcement of liquidated damages against bonds, and maximum penalties for brokers who fail due diligence, the financial consequence of any error rises materially. The practical effect is that proactive compliance is now far cheaper than reactive correction, because the relief that once softened penalties is being removed.
How does this order affect low-value and de minimis shipments?
The order hits low-value shipments hardest through the foreign IOR informal entry ban. Foreign IORs, which handle the majority of low-value import volume, are prohibited from filing informal entry entirely, the simplified process most low-value goods rely on. This compounds the earlier suspension of duty-free de minimis treatment.
Companies that moved low-value goods into the US through foreign IORs using informal entry will need a compliant US IOR or a CTPAT-validated broker to keep those flows moving. With de minimis already suspended and informal entry now closed to foreign IORs, the low-value import channel that operated with minimal oversight for years is being systematically closed. High-volume, low-value importers are the segment most exposed by the combined effect.
For companies importing IT hardware, medical devices, industrial equipment, and other regulated goods into the United States, the customs enforcement executive order makes the choice of importer of record a board-level supply chain decision. Carra Globe’s Importer of Record services operate with genuine US presence, the domestic asset and bonding backing the new rules demand, and the compliance infrastructure to keep your goods clearing while the market adjusts. To understand the IOR role in full before reviewing your current arrangement, see our explainer on what an Importer of Record is and does.
Disclaimer: This blog is for informational purposes only and does not constitute legal or customs advice. All details of the executive order are drawn from the official White House text of “Strengthening Customs Enforcement” dated June 3, 2026. Implementation specifics, including exact bond and asset thresholds, will be determined by US Customs and Border Protection through subsequent rulemaking. Always verify current requirements with a licensed customs broker or qualified trade counsel before making compliance decisions.