Executive Order Tightens CBP Requirements for U.S. Importers of Record

On June 3, 2026, President Trump issued the Executive Order  (EO) “Strengthening Customs Enforcement,” directing the Department of Homeland Security and U.S. Customs and Border Protection to tighten importer eligibility, bonding, disclosure, vetting and enforcement standards. The EO is framed largely around “foreign importer of record” risk, but it also establishes new baseline obligations for “U.S. importers of record” (U.S. IORs), including enhanced domestic asset and bond expectations, broader importer disclosures, a new CBP “good standing” requirement, and heightened supply-chain certification and reporting expectations.

Although many implementing details must still be issued through regulations, guidance or policy revisions, the EO requires action within 45 to 180 days and signals more rigorous scrutiny of importer eligibility, registry status, customs compliance history and product-level supply-chain information. U.S. IORs should begin preparing now.

Key new requirements for U.S. IORs:

(1) minimum tangible domestic asset and/or bond thresholds; (2) mandatory IOR designation and financial support for both formal and informal entries; (3) expanded ownership, affiliate, domestic asset and import-volume disclosures; (4) a new CBP-defined “good standing” requirement tied to compliance history; (5) enhanced registry review and recurrent vetting; and (6) heightened certifications and product-level supply-chain reporting, backed by more aggressive audits and penalties.

What is changing for U.S. IORs?

First, the president directed CBP to require all IORs to maintain minimum tangible domestic assets, bonding, or both, and to increase minimum bond coverage as needed to ensure compliance. Second, CBP must require a designated IOR—and a bond or sufficient domestic assets—for both formal entries under 19 U.S.C. § 1484 and informal entries under 19 U.S.C. § 1498. Third, U.S. IORs should expect expanded data submissions, including anticipated import volumes, year organized, ownership and beneficial ownership information, business affiliations and domestic asset disclosures, plus any additional information CBP deems necessary. Fourth, CBP must establish a “good standing” standard based on the importer’s and affiliates’ compliance history and customs payment record, and update the importer registry to remove inactive entities, confirm disclosures and create risk-based tiers. Finally, the EO directs heightened certification and reporting regarding supply chains, production methods and product identifiers, together with stronger enforcement, more audits and revised penalty practices.

What should companies do now?

U.S. companies should assess whether they can substantiate their U.S. presence and domestic assets to meet the criteria to be a U.S. IOR, test whether current bond levels remain adequate under higher duty exposure, organize ownership and affiliate data, review prior compliance issues that could affect future “good standing,” and identify supply-chain and product-level information that may be difficult to obtain from suppliers. Companies should also monitor CBP and DHS rulemaking and guidance closely over the next six months.

Contact Brownstein for assistance in performing a due diligence review to ensure that your company can continue to import goods by meeting the criteria for U.S. IOR.

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