The customs enforcement executive order: Importer guide

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On June 3, 2026, President Trump signed an executive order titled Strengthening Customs Enforcement — and it may be the most consequential shift in U.S. import compliance in a generation. With binding implementation deadlines beginning in as few as 45 days, trade compliance teams, customs brokers, and global importers face an immediate and urgent mandate: get your house in order, fast.

For companies that have invested in modern trade compliance infrastructure, this order is a manageable challenge. For those still relying on manual processes, spreadsheets, or disconnected systems, it is a definite warning.

Executive Order — June 3, 2026

“Systemic inefficiencies, loopholes, insufficient enforcement mechanisms, and outdated processes have created opportunities for malign actors to evade Federal law… The United States must strengthen its customs enforcement through comprehensive reform.”

What areas does the customs enforcement order cover?

The executive order directs sweeping reform across four dimensions: Importer of Record (IOR) accountability, supply chain disclosure and certification, enforcement and penalties, and transparency. Each area carries aggressive timelines.

45 days

By ~July 18, 2026

DHS submits legislative reform recommendations to the President

90 days

By ~September 1, 2026

New disclosure & certification requirements
Penalty floors set at 50% minimum
Foreign exporter documentation rules
Transparency reporting framework

180 days

By ~December 1, 2026

Revised IOR eligibility regulations
“Good standing” requirements enforced
Risk-tiered IOR registry goes live
Foreign IOR bond & CTPAT rules active

Importer of Record accountability

The order draws a sharp line between domestic and foreign importers of record. Foreign IORs are prohibited from filing informal (de minimis) entries and must either achieve Customs Trade Partnership Against Terrorism (CTPAT) validation or route through a CTPAT-validated customs broker for all formal entries. Continuous bonds, long the backstop of convenience for foreign importers, can no longer be relied upon as a blanket compliance mechanism.

Perhaps most consequentially, the order creates a formal “good standing” system for IORs — and makes loss of that status mean loss of import privileges entirely. IORs with violations involving fentanyl, contraband, or unpaid duties will be barred from importing. There is no gray zone here.

The compliance teams that will weather this shift are those with systems that give them visibility, documentation, and auditability — not those trying to reconstruct their compliance posture after an enforcement action.

What does this executive order mean for supply chain transparency?

Beyond IOR accountability, the order mandates certification of supply chain compliance — including forced labor statutes and the Countering America’s Adversaries through Sanctions Act (CAATSA) — at the point of import. It also requires submission of foreign exporter documentation previously filed with the exporter’s home customs authority. The message from Washington is unambiguous: know your supply chain, document it, and prove it at the border.

For most importers, this is not a simple checkbox. It requires deep integration between trade data, supplier records, classification systems, and entry management — the kind of integration that is structurally impossible to achieve through manual workflows or siloed systems.

What are the penalties for non-compliance with the customs enforcement order?

The executive order sets a minimum penalty floor of 50% of the assessed penalty, eliminates mitigation for repeat offenders, and instructs the Department of Homeland Security to maximize enforcement actions. Annual public transparency reports will make enforcement histories visible — creating reputational consequences on top of financial ones.

This is not a regulatory environment where a good-faith compliance effort earns forgiveness for inadequate systems. The government has explicitly stated its intent to close loopholes, pursue maximum penalties, and make enforcement visible. The risk of non-compliance has never been higher — and neither has the cost of getting it wrong.

Why ONESOURCE Global Trade is the answer

Thomson Reuters ONESOURCE Global Trade is purpose-built for exactly this kind of regulatory inflection point. For multinational importers, customs brokers, and global trade compliance teams, ONESOURCE provides the integrated infrastructure needed to meet these new requirements — not after the fact, but as a matter of operational standard.

Key ONESOURCE Global Trade modules

Import Management

Centralized control of entry data, IOR records, classification, and CBP submission — the foundation of compliance under this EO.

Denied Party Screening

Continuous screening of suppliers and partners against global watchlists — critical for CAATSA and forced labor certification.

Supply Chain Compliance

Map and document your supply chain with the depth and traceability required for forced labor attestations and origin certification.

Global Duty Optimization

Track duty obligations, bond requirements, and payment status — directly relevant to IOR “good standing” and new bond coverage rules.

Global Trade Visibility

Audit trail reporting and dashboards giving compliance teams real visibility into risk posture before CBP comes knocking.

Government Connectivity

Direct connectivity with CBP’s Automated Commercial Environment keeps data submissions current as CBP updates its schemas under this EO.

ONESOURCE Global Trade is not a point solution. It is the operational backbone that connects classification, entry management, duty liability, supply chain documentation, and partner screening into a single, auditable compliance infrastructure. When CBP comes asking — and this executive order makes that more likely, not less — ONESOURCE customers have answers.

The platform also integrates with CoCounsel, the Thomson Reuters AI-powered assistant, giving compliance teams access to regulatory interpretation, trade law guidance, and enforcement intelligence — directly within the Thomson Reuters ecosystem. In an environment where regulations are moving faster than most legal departments can track, that connectivity matters.

The moment to act is now — not at the 90-day deadline

The 90-day clock on new disclosure requirements, penalty floors, and foreign exporter documentation rules begins today. The 180-day clock on IOR eligibility reform, good standing enforcement, and risk-tiered registry changes is already ticking. Waiting for CBP to publish final guidance before beginning an internal compliance review is not a strategy — it is a gamble.

Companies that begin now — auditing their IOR data, assessing supply chain documentation gaps, reviewing their bonding structures, and confirming CTPAT status — will have options. Companies that wait will face compressed timelines, elevated scrutiny, and a regulatory environment with explicit instructions to enforce at maximum.

The executive order did not create the need for robust compliance infrastructure. It simply made the cost of not having it undeniable.

See ONESOURCE Global Trade in action