Hello Customers, Colleagues, and Friends,
On June 3, 2026, the White House issued an Executive Order titled “Strengthening Customs Enforcement” directing U.S. Customs and Border Protection (CBP) to develop new regulations, policies, and procedures related to Importers of Record (IORs), customs bonds, importer vetting, and customs enforcement.
At this time, no CBP regulations have changed and importers should continue operating under current requirements. However, the Executive Order establishes a roadmap for significant changes that CBP has been directed to implement over the coming months.
Potential Changes Under Consideration
- New restrictions and additional requirements for foreign Importers of Record, including possible limitations on informal entry filings.
- Increased importer disclosure requirements, including beneficial ownership, business affiliations, domestic asset information, and anticipated import volumes.
- Higher bond and financial responsibility requirements for Importers of Record.
- Creation of a CBP “good standing” requirement tied to compliance history and payment of customs liabilities.
- Enhanced importer vetting procedures and increased scrutiny of importer structures designed to qualify as U.S. Importers of Record.
- Additional supply chain, manufacturing, and export documentation requirements.
- Increased enforcement activity focused on undervaluation, transshipment, forced labor compliance, customs bonds, and importer accountability.
What Importers Should Do Now
No immediate action is required. However, importers should consider:
- Review your current Importer of Record structure and ownership information.
- Evaluate your existing customs bond sufficiency.
- Analyze your Internal customs compliance procedures and recordkeeping practices.
- Examine your documentation supporting valuation, classification, and country of origin declarations.
Krenz & Hannan International is actively monitoring CBP guidance, Federal Register notices, and CSMS messages related to these developments. We expect additional information to be released over the next 90-180 days as CBP develops implementation procedures.
Sincerely, Your friends at Krenz & Hannan International