Recently, the White House issued the Executive Order on Strengthening Customs Enforcement, directing the U.S. Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to advance customs enforcement reforms. The reforms will focus on enhancing reviews of importer identities, customs bonds, declaration documents, and trade compliance records.
The clear core signal of this policy is that U.S. Customs will further raise import compliance thresholds, particularly strengthening supervision over issues such as Importer of Record (IOR), Customs Bond, undervaluation, misclassification, origin circumvention, and illegal transshipment.
I. Stricter IOR Identity Verification
Going forward, CBP may require importers to provide additional background information, including company establishment date, ultimate beneficial owners, shareholder and affiliate information, U.S. business address, actual asset status, and projected import volume.
For U.S. domestic IORs, Customs will place greater emphasis on whether they are genuinely registered and operating, and possess the capacity to assume tariff and compliance responsibilities.
For foreign IORs, regulatory requirements will be significantly tightened. The Executive Order specifically mentions that foreign IORs may face stricter restrictions and additional reviews regarding informal entries, formal entries, and Bond usage.
II. Potential Increase in Customs Bond Requirements
For high-risk importers, foreign IORs, enterprises with a history of violations, or those with insufficient credit records, CBP may subsequently increase Bond amounts, require supplementary financial guarantees, or provide proof of U.S.-based assets.
This means that some importers may face higher Bond costs, increased document submission requirements, and stricter release reviews in the future.
III. Importer "Good Standing" Becomes a Key Focus
CBP will establish an importer good standing management mechanism, focusing on evaluating importers' tariff payment records, customs compliance records, penalty records, affiliate risks, and historical import performance.
If an importer fails to meet the relevant requirements, their normal import eligibility or customs clearance arrangements may be affected subsequently.
IV. Higher Risks of Undervaluation, Misclassification, and False Information
This Executive Order specifically highlights the intensified crackdown on undervaluation, misclassification, origin circumvention, illegal transshipment, false importer information, and the use of shell companies to evade responsibilities.
For exporters and importers, future declaration documents must be more truthful, complete, and consistent, especially regarding product names, HTS codes, values, origins, manufacturer information, payment records, and trade chain documents.
V. Our Company's Reminder
In response to the upcoming U.S. Customs regulatory trends, our company will further strengthen the review of customer information and cargo details. For high-risk commodities, incomplete documents, unverifiable IOR information, obviously abnormal values, or inconsistent declaration logic, we may request supplementary documents, advance tax payments, or suspend operations.
We recommend that customers prepare the following documents in advance:
Valid and truthful importer information
Accurate product descriptions, materials, intended uses, and images
Correct HTS codes and basis for declared values
Trade documents such as payment records, purchase contracts, invoices, and packing lists
Relevant compliance documents for products regulated by FDA, APHIS, EPA, DOT, etc.
Subsequent specific implementation rules shall be subject to the formal regulations, announcements, and operational guidelines issued by CBP and DHS. Our company will continue to monitor policy developments and assist customers in preparing for customs clearance compliance in advance to reduce the risks of inspection, detention, fines, and clearance delays.
