CBP Enforcement Reform Signals Major Changes for Importers of Record

President Trump has signed a new Executive Order directing U.S. Customs and Border Protection (CBP) to significantly strengthen customs enforcement and importer compliance requirements. The initiative is aimed at closing loopholes used to evade duties, combat undervaluation and misclassification, and improve accountability across global supply chains.

Under the order, CBP has 180 days to revise Importer of Record (IOR) regulations and policies. Proposed changes include higher bond requirements, minimum domestic asset thresholds, expanded importer identification and ownership disclosures, and additional supply chain reporting requirements.

Key provisions include:

• Increased bond requirements and financial responsibility standards for Importers of Record

• Expanded reporting of ownership, beneficial ownership, business affiliations, and anticipated import volumes

• New disclosure and certification requirements related to supply chain compliance, sanctions, and product sourcing

• Restrictions on foreign Importers of Record, including limitations on the use of continuous bonds

• Enhanced enforcement against undervaluation, misclassification, illegal transshipment, and forced labor imports

• Increased audits, stricter broker due diligence expectations, and stronger penalties for non-compliance

The Executive Order also states that importers not considered to be in “good standing” with CBP may be prohibited from importing goods into the United States.

While specific regulatory changes will be developed over the coming months, importers, customs brokers, and logistics providers should prepare for heightened scrutiny, increased documentation requirements, and more aggressive enforcement activity. Companies relying on foreign IOR structures, low-value entry strategies, or complex supply chains may face the greatest compliance impact.

Vilden will continue monitoring CBP's implementation efforts and provide updates as additional guidance becomes available.