On June 3, 2026, U.S. President Donald Trump issued an Executive Order entitled “ Strengthening Customs Enforcement .” This order announces a comprehensive reform of customs compliance frameworks to combat tariff evasion, misclassification of goods, undervaluation, and the use of forced labor.

The main points of the announcement include:

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Legal definition of importers

The regulation establishes a mandatory legal differentiation based on specific criteria of presence in the country:

• U.S. IOR (U.S. Importer of Record): A U.S. citizen, a lawful permanent resident, or an entity organized under U.S. law, located in the U.S. and whose majority beneficial owners are at all times U.S. citizens or lawful permanent residents. An entity that owns a significant amount of U.S. real estate also qualifies as such. To be considered “located in the U.S.” requires a principal place of business in the U.S., a physical presence with significant business activity, and sufficient local tangible assets.
• Foreign IOR (Importer of Record): Any individual or entity that does not meet any of the above conditions.

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Compulsory measures applied to
foreign importers (Foreign IOR)

Foreign companies acting as importers in the U.S. are subject to the following provisions regulated by the order:

• Informal Entry Prohibition: Foreign importers are prohibited from submitting informal entries for low-value items. All their shipments must be processed through the formal entry channel.
• Continuous bond restriction: For formal entries, foreign importers may not use acontinuous bond to cover entry requirements, except when authorized by Customs and Border Protection (CBP) upon a showing that the proceeds are protected and compliance is assured.
• Certification requirement or specialized agent: The foreign importer must be validated in the CTPAT(Customs Trade Partnership Against Terrorism) program or, failing that, must use a licensedcustoms broker validated in CTPAT to process its entries.
• Asset guarantees and surety bonds: A minimum level of U.S. domestic tangible assets, surety bonds, or both are required to be maintained at all times, increasing the minimum required coverage of customs bonds.

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New information and document requirements (Deadline: 90 days)

The following transparency requirements will be implemented:

• Documentation from the country of origin: Mandatory submission to U.S. Customs of any documents or information that the foreign exporter had to submit to the customs administration of his own country prior to exporting to the U.S.
• Structural and tax data: Disclosure of beneficial ownership, business affiliations, domestic assets, foreign tax identifiers and global business identifiers.
• Detailed product information: Provision of data on production methods and supply chain, including the manufacturer’s product identifier (model number or style) and technical specifications such as composition, grade or size.