June 19, 2026

Executive Order: “Strengthening Customs Enforcement”

The White House issued an executive order overhauling who can serve as an Importer of Record (IOR) and how entries are vetted. The directive could have a major impact on Canadian businesses currently acting as FIORs (foreign importers of record) in the USA. 

Key changes:

• Higher eligibility bar. by Nov. 30, 2026, CBP must require every IOR to hold minimum tangible domestic assets or bonding, file expanded disclosures, and maintain “good standing.”
• Foreign vs. U.S. IORs
  • The EO defines a U.S. IOR as one whose controlling beneficial owners are U.S. citizens or lawful permanent residents, or — for an entity — that owns a significant amount of U.S. real property.
  • Foreign IORs are prohibited from filing informal entries (generally shipments under $2500) under 19 U.S.C. 1498
  • A foreign IOR may not rely on a continuous bond to meet the bond requirements for entry, except as permitted by CBP when the foreign IOR has demonstrated that the revenue would be fully protected and that compliance with the laws, regulations, and instructions enforced by CBP would be assured
  • For formal entry, a foreign IOR must also be validated in CBP’s Customs Trade Partnership Against Terrorism (CTPAT) program – if determined by CBP to be eligible – or use a CTPAT-validated and licensed customs broker (such as Carson) to file entries with CBP

The E.O. is a directive issued to CBP, and the exact details have yet to be confirmed. You can read the EO online here.