Original Coverage & Source Attribution: www.globaltrademag.com
Importers have traditionally treated customs compliance as a transaction-level exercise. Simply classify the product, calculate the duty, file the entry, and keep the records. That model is now becoming difficult to sustain.
Read also: Customs Regulations, Compliance, and Import Export Strategies
Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026, directs the Department of Homeland Security and US Customs and Border Protection to fundamentally expand the information, documentation, and accountability associated with Importers of Record (IORs). The order places greater emphasis on who is importing, who owns the importing entity, what assets it maintains in the United States, who its affiliates are, and what can be demonstrated about the origin and movement of imported goods.
For importers, the significance extends well beyond another regulatory checklist. The changes point toward a customs environment where traceability, data accuracy, and the ability to reconcile information across the supply chain become core compliance requirements.
The IOR Is Under Greater Scrutiny
Executive Order 14411 directs CBP to revise importer eligibility requirements within 180 days. Among other provisions, the order calls for IORs to maintain minimum levels of tangible domestic assets, bonding or both, while also providing additional information about anticipated import volumes, organizational history, ownership, beneficial ownership, business affiliations, and domestic assets.
The order also establishes a “good standing” framework for IORs and directs CBP to update the IOR registry, remove inactive importers, confirm compliance, and establish risk-based tiers based on factors including compliance history, enforcement actions, and audit results. Enhanced vetting is also contemplated for importers, affiliates, customs brokers, custodians of bonded merchandise, and freight forwarders. That makes the accuracy of basic importer information more consequential.
CBP has already begun putting this emphasis into practice. In an August 2026 notice, CBP announced enhanced enforcement of IOR information submitted through CBP Form 5106. Beginning September 18, 2026, CBP stated that inaccurate or incomplete information could result in the immediate voiding of an IOR number, preventing the importer from using that number to enter merchandise into the United States.
In other words, the first question in a compliance program very well may be: Can you prove who you are?
Foreign Importers Face Additional Requirements
The executive order directs DHS and CBP to impose additional requirements for foreign IORs. It directs DHS to prohibit foreign IORs from filing informal entries. For formal entries, foreign IORs generally would not be permitted to rely on a continuous bond unless CBP determines that the revenue would be fully protected and compliance assured. The order also directs foreign IORs to participate in CTPAT where eligible or use a CTPAT-validated and licensed customs broker.
For multinational companies, this creates an important distinction between having a presence in the United States and being able to demonstrate the characteristics required to qualify as a US IOR.
The executive order specifically directs DHS to develop guidance addressing what it means for an entity to be “located in the United States,” including consideration of its principal place of business, physical presence, and sufficient tangible US assets. That means corporate structure, ownership, and operational information are becoming part of the customs compliance conversation.
The Documentation Requirement Could Change the Data Burden
Perhaps the most consequential development for day-to-day compliance teams is the push toward greater visibility into documentation generated before goods ever reach the United States. Executive Order 14411 directs DHS to establish a requirement for submission of information or documentation that a foreign exporter was required to provide to its foreign customs administration before exporting goods to the United States.
CBP’s September 2, 2026 Advance Notice of Proposed Rulemaking provides more detail about what this could mean. The agency is considering whether importers should submit or retain foreign export documentation such as:
- Foreign export declarations
- Commercial invoices
- Packing lists
- Certificates of origin
- Export licenses and permits
- Bills of lading and air waybills
CBP says this information could help the agency reconcile import entries with information provided to foreign customs authorities and identify discrepancies that could indicate violations, including potential dual invoicing.
Importantly, CBP has not yet finalized a universal requirement covering all of these documents. The ANPRM is asking the trade community how such a requirement should work, whether documentation should be submitted with an entry or simply retained, who should be responsible for maintaining it, how authenticity should be verified and what compliance costs would result.
The comment period closes December 1, 2026.
For importers, that date should therefore be viewed as a major regulatory milestone and preparation point, rather than a blanket deadline to begin submitting every foreign export document to CBP.
Traceability Becomes a Compliance Capability
The implications extend beyond document storage. CBP is explicitly asking for input on technology that could improve supply chain traceability and visibility into the parties involved in imported goods. The agency is considering ways to connect information about manufacturers, exporters, intermediaries, and other parties across the import transaction. That raises a practical challenge for compliance teams.
The necessary information often exists, but it may be scattered across an ERP, broker systems, supplier portals, spreadsheets, product databases, emails, and foreign documentation. Different systems may contain different product descriptions, values, classifications, or country-of-origin information. A compliance team cannot effectively reconcile data that it cannot find.
This is where trade compliance technology can become more than a classification tool. Companies need a system that can connect product-level information with tariff classifications, regulatory requirements, and changes that could affect an entry.
Reasonable Care Gets More Complicated
Author bio
Shannon Hynds is the Co-Founder/ CEO of Quickcode.ai, an AI-powered platform built to help organizations make sense of complex, text-heavy data. With a background in software engineering and product leadership, Shannon brings deep technical expertise to solving real-world problems. She is passionate about capturing the knowledge of SMEs, giving teams access to the best information available.
