With Executive Order 14411 of June 3, 2026, the U.S. Administration launched a comprehensive review of customs regulations, with particular focus on both U.S. and foreign entities acting as Importers of Record (IORs). The objective is to strengthen import security, prevent the entry of dangerous or illegal goods, and ensure the proper payment of customs duties.

The reform aims a review of requirements concerning importer identification, financial standing, supply chain traceability, and compliance with U.S. customs and trade regulations, with the aim of ensuring adherence to U.S. legal requirements. For foreign IORs, the possible introduction of more restrictive measures by U.S. Customs and Border Protection (CBP) is expected. Among the proposed measures are new operational limitations, increased reporting obligations, and the requirement to obtain Customs Trade Partnership Against Terrorism (CTPAT) certification or, alternatively, to engage a CTPAT-certified customs broker.

The Executive Order of June 3 directs CBP to adopt the administrative measures necessary to implement its provisions by the end of november 2026. At present, not all implementing regulations have been published and are likely to be introduced through several administrative measures. However, an important operational deadline has already been established: starting September 18, 2026, CBP may immediately deactivate an IOR number if the information provided in CBP Form 5106 is found to be inaccurate or incomplete. A deactivated IOR number cannot be used for import operations into the United States until the information has been corrected and the IOR has been reinstated by CBP.

Entities importing goods into the United States are therefore encouraged to promptly verify the accuracy of the following information:

• Full legal name of the company;
• EIN, Tax ID, or CBP-assigned identification number;
• Physical business address of the importer;
• Mailing address;
• Telephone number;
• E-mail address directly attributable to the Importer of Record;
• Corporate structure, beneficial ownership, and information regarding company directors/officers;
• Validity of the Power of Attorney, namely the customs representation authorization granted directly to the customs broker.

Particular attention should be paid to the e-mail address registered with CBP. Communications regarding verification requests or the possible deactivation of an IOR number are sent to the contact information available in CBP systems. The e-mail address must belong directly to the importer; it is not permissible to use the e-mail address or physical address of a customs broker, freight forwarder, or any other third party.

Each IOR should login to its ACE portal account and verify within the “importer sub-account” that all information in the “contacts and addresses” tabs are accurate and up to date.

Updating CBP Form 5106 represents only the first step in implementing the June 3 Executive Order. The strengthening of customs controls will involve a broader assessment of an importer’s identity, ownership structure, business relationships, ability to meet customs duty and other financial obligations, as well as customs compliance and supply chain security for both domestic and foreign IORs. Foreign IORs may subsequently be subject to additional restrictive measures, including:

• Prohibition on using informal entries, which are simplified import clearance procedures for low-value shipments;
• Requirement to use only formal entries and prohibition on using a continuous bond, the annual customs bond designed to facilitate frequent importers, unless specifically authorized by CBP;
• Obligation to obtain CTPAT certification or to use a CTPAT-certified customs broker when conducting import operations.

At this initial stage, companies operating as foreign IORs in the United States should first focus on promptly reviewing and updating their IOR information, ensuring its accuracy and consistency with corporate and tax records by September 18, 2026.

In anticipation of potential changes to the requirements for operating in the United States, Importers of Record should begin collecting supporting documentation relating to ownership, business affiliations, import activities, and supply chain operations. They should also assess their CTPAT status or verify that their customs broker holds a valid CTPAT certification.