Customs enforcement is changing. Importers should prepare before the rules become operational.

On June 3, 2026, the White House issued an Executive Order titled Strengthening Customs Enforcement. The order directs the Department of Homeland Security and U.S. Customs and Border Protection to pursue a broad customs enforcement reform effort focused on Importers of Record, bond coverage, supply chain disclosures, foreign IORs, audits, penalties, and import transparency.

For U.S. importers, this is an important signal.

Customs compliance is no longer just a final step before cargo release. It is becoming a bigger part of supply chain risk management. Importers that rely on incomplete product data, weak documentation, unclear supplier visibility, or outdated customs processes may face more friction as enforcement expectations increase.

The order does not mean every rule changes overnight. Many of the directives require agency action, updated guidance, or rulemaking. However, importers should not wait until new requirements are finalized to review their process. The companies that prepare early will be better positioned to reduce delays, avoid penalties, and keep freight moving.

At GLC Inc., our Customs Brokerage team helps importers manage the entry process with stronger visibility, cleaner documentation, and compliance-focused coordination.

Why this order matters for importers

The Executive Order focuses on a core issue: importer accountability.

The Importer of Record is responsible for making sure goods are entered correctly, duties and fees are paid, and information submitted to CBP is accurate. That includes details such as classification, valuation, country of origin, product descriptions, and other data required for admissibility.

CBP already emphasizes the concept of “reasonable care” for importers. In practice, this means companies should have a process for reviewing customs information before cargo arrives, not after a problem appears. Importers can review CBP’s guidance on reasonable care and basic importing requirements to better understand existing responsibilities.

The new Executive Order builds on that foundation by directing agencies to increase scrutiny in several areas that directly affect importers.

1. Importer of Record eligibility may face tighter standards

One of the most important parts of the order is the review of Importer of Record eligibility.

The order directs DHS and CBP to revise importer eligibility regulations, guidance, and policies within 180 days. These revisions may include higher bond coverage, minimum tangible domestic asset requirements, additional identification details, anticipated import volume information, ownership disclosures, beneficial ownership details, business affiliations, and domestic asset disclosures.

For importers, this means the basic question of “who is acting as the Importer of Record?” may become more important.

Companies should review whether their IOR structure is clear, properly documented, and aligned with the way their shipments are actually moving. If the importer listed on the entry does not have the right documentation, financial accountability, or operational control, that structure may create risk.

2. Foreign IORs may face stricter limitations

The order pays special attention to foreign Importers of Record.

It directs CBP to restrict foreign IORs from filing informal entries and to place additional requirements on foreign IORs using formal entry. These requirements may include stronger bonding conditions and, when applicable, use of a CTPAT-validated and licensed customs broker.

For e-commerce sellers, overseas manufacturers, foreign suppliers, and companies using non-U.S. entities to import into the United States, this is a major area to monitor.

Importers should review whether they are relying on a foreign IOR model and whether that model could be affected by future CBP guidance. Companies can also review CBP information on CTPAT to understand how the program relates to supply chain security and trusted trade practices.

3. Product data and supply chain documentation may become more important

The order also directs DHS and CBP to establish heightened import disclosure and certification requirements.

This may include more detailed information about product identifiers, model numbers, specifications, composition, grade, size, production methods, foreign tax identifiers, global business identifiers, and documentation submitted to foreign customs authorities before export to the United States.

For importers, this creates a clear takeaway: product data needs to be organized before the shipment moves.

A vague commercial invoice, inconsistent product description, missing HTS support, unclear country of origin, or incomplete supplier documentation can create delays. In a stricter enforcement environment, those gaps may also increase audit or penalty exposure.

Importers should review whether their internal teams, suppliers, and customs broker are working from the same product data. This is especially important for companies with high SKU counts, multiple suppliers, regulated products, seasonal inventory, or growing e-commerce volume.

4. Bond coverage should be reviewed early

The order includes language around increasing minimum bond coverage for Importers of Record and requiring bonds or sufficient tangible domestic assets for formal and informal entries.

That makes bond readiness a practical priority.

A customs bond is not just an administrative requirement. It helps secure payment of duties, taxes, and fees owed to CBP. If bond coverage is insufficient, inactive, or not properly aligned with import activity, cargo movement can be disrupted.

Importers that ship frequently should review whether their continuous bond reflects current import volume, duty exposure, tariff changes, and growth plans. Importers relying on single-entry bonds should also evaluate whether their process is creating avoidable delays.

GLC recently covered this topic in our blog, Customs Clearance Starts Before Arrival, where we explained why bond and payment readiness should be checked before cargo is already approaching the port.

5. Penalties, audits, and enforcement activity may increase

The Executive Order directs CBP to increase audits, enforce liquidated damages claims, restrict in-bond utilization, and prioritize enforcement against forced labor, misclassification, undervaluation, and illegal transshipment.

It also directs CBP to revise mitigation standards and establish a minimum penalty floor of at least 50% of the assessed penalty in many cases, absent exceptional circumstances.

That means importers should treat compliance gaps as financial risks.

Misclassification, undervaluation, incorrect origin declarations, late filings, or missing documentation can affect more than one shipment. They can create a pattern that exposes the importer to greater scrutiny.

The best response is not panic. The best response is preparation.

What importers should review now

Before new requirements become operational, importers should review five areas of their customs process:

First, confirm who is acting as the Importer of Record and whether that structure is properly documented.

Second, review customs bond coverage and confirm that it matches current import activity.

Third, audit product data, including HTS classifications, country of origin, product descriptions, supplier details, and supporting documentation.

Fourth, evaluate whether foreign suppliers or overseas entities are involved in the IOR process.

Fifth, improve visibility into customs milestones, including ISF submission, entry processing, release notifications, and reporting.

These steps can help importers reduce unnecessary friction and prepare for stricter enforcement expectations.

How GLC helps importers prepare

GLC’s Customs Brokerage team helps importers move with greater confidence through a compliance-focused approach to customs coordination.

Our services include import entry processing, Importer Security Filings, continuous bond management, TIB entry processing and management, direct ACH setup with U.S. Customs and Border Protection, periodic monthly statements, and government confidentiality requests.

Just as important, GLC provides visibility through ISF submission notifications, customs entry processed notifications, release notifications, and reporting tools that help importers stay informed throughout the clearance process.

For companies managing international freight, customs compliance cannot be separated from the rest of the supply chain. The right customs strategy can help reduce delays, improve documentation accuracy, and support better planning across ocean freight, air freight, trucking, warehousing, and distribution.

Explore GLC’s full range of freight forwarding and logistics services to see how our team supports importers from origin to final delivery.

Final takeaway: review before enforcement creates friction

The new customs enforcement order is a reminder that import compliance is becoming more data-driven, more accountable, and more closely tied to financial risk.

Importers do not need to wait for disruption to review their process. Now is the time to check IOR structure, documentation quality, bond coverage, supplier data, classification practices, and customs visibility.

A stronger customs process starts before cargo arrives.

Review your import strategy with GLC.

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