The Customs Enforcement Overhaul: 7 Changes Every Importer Faces by December

On June 3, 2026, President Trump signed an executive order that CBP summarized in five words: "Importing is a privilege, not a right." The "Strengthening Customs Enforcement" order gives DHS and CBP 180 days to rewrite importer eligibility rules — meaning by early December, your bond requirements, registration data, and standing with CBP could all look dramatically different. Here's exactly what's coming and what you need to do now.

For years, the customs bond system operated on a simple bargain: post a $50,000 continuous bond, file your entries, and CBP trusts you'll pay what you owe. That era is ending.

The June 3 executive order doesn't just tweak the system — it rebuilds the foundation. Every Importer of Record (IOR) operating in the United States will face new asset requirements, new data disclosures, and a new "good standing" standard that CBP can use to restrict or revoke import privileges. Foreign IORs face even harsher treatment: no more informal entries, no more continuous bonds (with narrow exceptions), and a mandate to either join CTPAT or hire a CTPAT-validated broker.

The order cites "systemic inefficiencies, loopholes, insufficient enforcement mechanisms, and outdated processes" that have allowed duty evasion, undervaluation, and forced labor goods to slip through. Whether you agree with the framing or not, the compliance obligations are real — and the deadlines are aggressive.

What Triggered This Order

The executive order identifies several categories of abuse that motivated the overhaul:

• Undervaluation of imports — declaring goods below actual transaction value to reduce duties
• Withholding critical IOR information — shell entities filing entries with no traceable beneficial owner
• Duty evasion through transshipment — routing goods through third countries to avoid country-specific tariffs
• Forced labor imports — circumventing Withhold Release Orders (WROs) under Section 307
• Exploitation of informal entry procedures — using the $2,500 threshold to avoid scrutiny

CBP has been vocal about enforcement gaps for years. The agency's own data shows that duty evasion costs the U.S. Treasury billions annually. This order gives CBP the legal backing to demand more from importers — and the mandate to act within specific timelines.

The 180-Day Clock: What Changes for All Importers

Within 180 days of June 3 (approximately December 1, 2026), DHS must revise importer eligibility regulations. These changes apply to every IOR, domestic or foreign:

1. Minimum domestic assets or increased bonding. All IORs must maintain a minimum level of tangible domestic assets, bonding, or both. The current $50,000 continuous bond minimum — unchanged for decades despite massive tariff increases — will rise. If your annual duties have spiked due to Section 301 or IEEPA tariffs, expect your bond formula (typically 10% of annual duties, taxes, and fees) to be recalculated upward.

2. Mandatory IOR designation for all entries. Currently, some informal entries (goods valued under $2,500) don't require a named IOR with a bond on file. That's ending. Every entry — formal or informal — will require a designated IOR reported to CBP with sufficient assets or bonding.

3. A new "good standing" requirement. CBP will define "good standing" based on the IOR's (and its affiliates') compliance history, payment record, and other factors. Importers who fall out of good standing could face restricted entry privileges, higher bonds, or loss of import eligibility entirely.

4. Enhanced registration data. IORs must provide CBP with additional information including anticipated import volumes, ownership structure, and beneficial ownership disclosures.

The Foreign IOR Lockout

The order reserves its most aggressive provisions for foreign-based importers of record. If your company is a foreign entity importing into the U.S. — or if you rely on a foreign supplier acting as IOR — these changes are seismic:

The practical effect: a foreign entity that currently files informal entries for low-value e-commerce shipments will either need to establish a U.S. presence, join CTPAT, or hire a CTPAT-validated customs broker for every single entry. The order explicitly cites "higher volumes of low-value articles from foreign importers" and "the difficulty of enforcing penalties against entities with assets overseas" as justification.

The 90-Day Disclosure Mandate

A separate, faster deadline hits around September 1, 2026: within 90 days, DHS must establish a requirement for importers to submit documentation proving that the foreign exporter provided required information to the foreign customs administration before export.

This is a new layer of paperwork. You'll need to demonstrate that your overseas supplier filed proper export declarations with their own government before the goods shipped. If you can't produce that documentation, expect holds, exams, or entry rejections.

What "Good Standing" Likely Means

CBP hasn't published its formal definition yet, but the order specifies the criteria will include:

• Compliance history — past violations, penalties, seizures, and prior disclosures
• Affiliates' compliance — if your parent company, subsidiaries, or related entities have violations, that counts against you
• Payment record — late duty payments, outstanding liquidated damages, or unpaid penalties
• Other considerations — likely including response to CBP requests for information, participation in Focused Assessments, and audit cooperation

This isn't unprecedented — CBP already uses a risk-scoring system internally. But formalizing "good standing" as a gateway requirement for import privileges is new. An importer who loses good standing could face anything from increased bond requirements to a full suspension of entry privileges.

Who Gets Hit Hardest

E-commerce platforms using foreign IORs. Companies that built import models around foreign entities filing high volumes of informal entries will need to restructure entirely. The combination of no informal entry and no continuous bonds effectively forces these operations to either establish U.S. IOR entities or contract with domestic CTPAT brokers.

Small importers with thin margins. If your $50,000 continuous bond jumps to $100,000 or $200,000 based on new minimums, that's real money — especially if your surety requires collateral. Bond premiums will rise across the industry.

Importers with compliance baggage. The "good standing" requirement means that penalty from three years ago, or that unresolved prior disclosure, suddenly has new consequences. Cleaning up your compliance record just became urgent.

Companies with complex ownership structures. Beneficial ownership disclosure requirements mirror the Corporate Transparency Act approach — expect to report ultimate beneficial owners, not just the entity name on the bond.

What to Do Before December 1

1. Audit your bond sufficiency now. Calculate 10% of your projected annual duties under current tariff rates. If you're above your current bond amount, your surety may demand an increase regardless of the new rules. Get ahead of it.

2. Map your IOR structure. If you use a foreign entity as IOR for any entries — even a small volume — start planning the transition now. Options: establish a U.S. subsidiary as IOR, shift to a domestic IOR arrangement with your customs broker, or begin CTPAT enrollment (which takes 6-12 months).

3. Clean up outstanding compliance issues. File overdue prior disclosures. Pay outstanding penalties or negotiate mitigation. Resolve any open Focused Assessment findings. When CBP defines "good standing," you want a clean slate.

4. Prepare beneficial ownership documentation. Identify your ultimate beneficial owners and corporate affiliations. Draft the disclosures now so you're not scrambling when the regulations drop.

5. Contact your customs broker about CTPAT. If your broker isn't CTPAT-validated, ask about their timeline. If you're a foreign IOR planning to continue importing, CTPAT validation (for you or your broker) is no longer optional — it's a hard requirement.

6. Build your export documentation process. The 90-day disclosure rule means you need a system to collect and retain foreign export declarations from every supplier. Start requesting these documents now so the process is routine by September.

7. Budget for higher compliance costs. Between increased bonds, potential CTPAT enrollment, additional documentation requirements, and possible broker fee increases, compliance costs are going up. Factor this into Q4 2026 and 2027 planning.

What's Coming Next

The executive order also directs DHS to submit legislative recommendations to Congress for additional enforcement tools. While legislation takes longer than rulemaking, expect proposals around:

• Increased civil and criminal penalties for duty evasion
• Expanded authority to deny or revoke IOR status
• New tools for combating transshipment and origin fraud
• Enhanced data-sharing between CBP and foreign customs authorities

Meanwhile, watch for a Notice of Proposed Rulemaking (NPRM) from CBP — likely in late summer or early fall — with the specific details on bond amounts, good standing criteria, and foreign IOR requirements. That's your window to submit public comments.

The enforcement trajectory is clear: CBP is moving from a trust-based system to a verify-first system. Importers who treat this as a paperwork exercise will get caught flat-footed. Those who use the next six months to strengthen their compliance infrastructure will find the transition manageable — and may even benefit from the competitive advantage of being in good standing while others scramble.

The Bottom Line

This executive order is the most significant structural change to importer obligations since the Customs Modernization Act of 1993. It won't hit all at once — rulemaking takes time, and there will be comment periods — but the direction is unmistakable: higher bars to entry, deeper disclosure requirements, and real consequences for non-compliance.

The importers who come through this strongest are the ones who start preparing now, not the ones who wait for the final rule. TariffLens is building tools to help importers track their compliance posture and bond adequacy as these rules develop — because when "good standing" becomes a formal requirement, you'll want to know exactly where you stand.

This article is for informational purposes only and does not constitute legal, tax, or customs advice. Consult a licensed customs broker or trade attorney for guidance specific to your situation.