Trump Order Tightens U.S. Import Rules for Foreign Companies

Companies that act as their own U.S. Importer of Record or rely on “tax-included,” “double-clearance,” or DDP services could be affected by a new U.S. policy.

President Trump has signed an executive order directing U.S. Customs to revise Importer of Record eligibility, customs bond requirements, import disclosure rules, and penalties for customs violations. The changes affect manufacturers exporting to the United States, cross-border e-commerce sellers, and U.S. companies importing goods from overseas. （whitehouse.gov）

Foreign Companies Will Face Higher Importer of Record Requirements

The Importer of Record (IOR) is the party legally responsible for goods imported into the United States. Under new rules, it will become much more difficult for foreign companies to act as their own IOR.

To qualify as a U.S. IOR, a company must generally:

• Be organized under U.S. law

• Have its principal place of business and substantial operations in the United States

• Maintain sufficient U.S. tangible assets

• Be controlled by U.S. citizens or permanent residents

A company may also qualify by owning a specified amount of U.S. real estate.

Foreign companies that do not qualify as U.S. IORs may still operate as foreign IORs. However, foreign IORs will also face stricter requirements. They will need to hold a minimum amount of tangible assets in the United States or provide a larger customs bond.

As of June 18, 2026, the exact asset and bond thresholds had not been announced. The Department of Homeland Security is required to move forward with the rule changes by November 30, 2026.

Informal Entry and Continuous Bonds Will Be Restricted

One of the main restrictions involves informal entry, which generally applies to imported goods valued below $2,500 and requires fewer customs procedures. Foreign Importers of Record may lose access to informal entry and be required to use formal entry instead. However, their ability to meet formal-entry bond requirements will also become more limited.

Foreign Importers of Record may no longer be able to rely on a Continuous Bond unless they can prove ongoing compliance with U.S. customs laws, regulations, and duty-payment requirements.

They will also need CTPAT validation. Without it, they must use a customs broker that has already been validated under CTPAT.

Customs Will Continuously Review Importers

Obtaining Importer of Record status will not be the only requirement. U.S. Customs will also assess whether importers remain in good standing.

The review will consider their compliance history, the records of affiliated companies, payment of duties and other customs debts, and other factors. Customs will also assign risk classifications.

Importers that lose good standing will no longer be allowed to import goods into the United States or appoint a customs broker to act as Importer of Record on their behalf.

Companies Will Face More Disclosure and Higher Penalties

The policy will also require companies to provide more information. They may need to disclose projected import volume, corporate and beneficial ownership, affiliated companies, U.S. assets, and detailed product information.

By September 1, 2026, foreign sellers may also be required to provide U.S. Customs with the export declaration information submitted to their local customs authorities.

At the same time, penalty relief will be reduced. Final penalties generally cannot fall below 50% of the original assessed amount, except in special cases involving significant national security risks.

U.S. Customs will also increase audits and prioritize investigations involving forced-labor goods, misclassification, undervaluation, and illegal transshipment.

What Companies Should Do

Companies should first confirm whether their current Importer of Record will remain eligible. They also need to determine what alternative they will use if informal entry is no longer available, whether their Continuous Bond can still be used, and how changing the Importer of Record or bond arrangement will affect quotations and customs clearance times.

They should also organize supply chain records and standardize product names, customs codes, declared values, countries of origin, manufacturers, models, materials, and uses.

Any problems involving product classification, declared value, or country of origin should be corrected before the new standards take effect.