On June 3, 2026, President Trump issued an executive order directing the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to revise the federal government's Importer of Record regulations, policies, and agency guidance. The order signals a significant shift in U.S. customs enforcement priorities and is expected to impose new restrictions on foreign importers as part of a broader effort to strengthen oversight at the U.S. border.
The Importer of Record designation is a foundational element of U.S. customs compliance. The party serving as Importer of Record is legally responsible for ensuring that imported goods comply with all applicable laws, that accurate entry information is provided to CBP, and that duties, taxes, and fees are properly paid. Because this role carries substantial legal and financial exposure, changes to the underlying regulatory framework can have far-reaching consequences for importers, customs brokers, and the multinational supply chains that depend on them.
While the implementing regulations have not yet been issued, the executive order makes clear that foreign importers will face heightened scrutiny. Companies that currently rely on non-resident Importers of Record, or that use structures involving foreign affiliates to bring goods into the United States, should anticipate forthcoming requirements that may limit eligibility, expand documentation obligations, or impose additional bonding, security, or vetting standards. The order also directs DHS and CBP to align agency guidance with the policy objectives of tighter customs enforcement, suggesting that internal CBP procedures and risk-targeting practices will evolve in parallel with formal rulemaking.
Importers should begin reviewing their current Importer of Record arrangements, customs power-of-attorney structures, and broader trade compliance programs in advance of any new requirements. Particular attention should be given to supply chain mapping, recordkeeping practices, and the allocation of legal responsibility among foreign sellers, U.S. buyers, and third-party logistics providers. Engaging with customs brokers and trade counsel early will help organizations identify exposure points, evaluate alternative import structures, and prepare for prompt compliance once revised regulations are published.
This update is provided for general informational purposes only and does not constitute legal advice. Clients facing customs or import-related questions should seek tailored guidance based on their specific operations and risk profile.