Executive Order 14411, “Strengthening Customs Enforcement,” tightens who can import into the United States and how they are vetted. The most immediate change: starting January 5, 2027, a foreign importer of record may enter goods only if it is validated under CTPAT (the Customs Trade Partnership Against Terrorism) or uses a CTPAT-validated licensed customs broker. U.S. importers face tougher data-accuracy rules now.
An importer of record (IOR) is the party legally responsible for an import entry: for the duties, the data, and the compliance. If you import, sell DDP (delivered duty paid), or let a foreign supplier import on your behalf, these rules reach you.
Why the Order Was Issued
President Trump signed EO 14411 on June 3, 2026, and it was published in the Federal Register on June 10, 2026 (91 FR 35125). The Order calls customs enforcement essential to national security, foreign policy, and the economy. It points to undervaluation, withheld information about importers and goods, and duty-avoidance schemes as the gaps to close.
The EO does not change duty rates. It changes who may import, what they must disclose, and how hard CBP will enforce.
What the Order Directs
| Area | What the EO directs | Where it stands |
|---|---|---|
| IOR eligibility (Sec. 2(a)) | Minimum domestic assets, bonding, or both; higher minimum bond coverage; more disclosure (ownership, beneficial owners, affiliations, expected import volume) | Due within 180 days (November 30, 2026); rulemaking pending |
| Foreign IORs (Sec. 2(b)-(c)) | Bar foreign IORs from informal entries; for formal entries, no continuous bond unless CBP is satisfied revenue is protected, and CTPAT validation or a CTPAT-validated broker | Interim final rule published November 6, 2026 |
| Good standing (Sec. 2(d)) | IORs not in good standing cannot import or name a broker as IOR | Due within 180 days; definition pending |
| IOR registry and vetting (Sec. 2(e)-(f)) | Remove inactive IORs; risk-tier the rest; recurring vetting of foreign IORs, affiliates, brokers, bonded-merchandise custodians, and freight forwarders | Due within 180 days |
| Import disclosure (Sec. 3) | Certifications, foreign tax and business identifiers, supply-chain and production detail, and the documents a foreign exporter filed with its own customs authority | Proposed (advance notice published September 2, 2026) |
| Enforcement and penalties (Sec. 4) | Stronger enforcement against bonds, in-bond use, and brokers; penalty mitigation floor of at least 50%; no mitigation for repeat offenders | Directed; 90-day mark was September 1, 2026 |
| Disposal and transparency (Secs. 5-6) | Faster seizure and disposal of noncompliant goods; annual enforcement reports | Directed |
New Rules for U.S. Importers of Record
1. Accurate CBP Form 5106 data, enforced now. Since September 18, 2026, CBP can void an IOR number when the importer’s Form 5106 data is inaccurate or incomplete. A voided number is invalid for any purpose, including entering goods. The physical address must be the importer’s actual location, not a registered agent, customs broker, freight forwarder, P.O. box, or business service center. The email and phone must belong to the importer, not the broker (91 FR 53627).
2. You must prove you are a “U.S. IOR.” The interim final rule defines a U.S. IOR as a U.S. citizen or lawful permanent resident, or an entity that is organized under U.S. law, located in the United States, and at all times either (a) has at least 51% of its beneficial owners as U.S. citizens or lawful permanent residents who control it, or (b) directly owns a significant amount of unencumbered U.S. real property. A U.S. address, EIN, or subsidiary alone does not qualify. U.S. IORs must declare their status on entry and entry summary. An inaccurate declaration can cost you immediate-delivery privileges.
3. U.S. IORs do not need CTPAT validation and may continue to use a broker that is not CTPAT-validated. Brokers, however, must now verify each client’s status before filing.
4. More disclosure is coming. CBP’s September 2 notice asks whether importers should submit foreign export documents (such as export declarations and commercial invoices), identify the manufacturer, shipper, exporter, and ultimate recipient for each shipment, and use global business identifiers. It is a request for comment, not yet a rule.
New Rules for Foreign Importers of Record
A foreign IOR is any IOR that does not meet the U.S. IOR test above.
- From January 5, 2027, a foreign IOR may enter goods for consumption only if it is CTPAT-validated or designates a CTPAT-validated, licensed customs broker to make entry for it.
- Reports on the rule indicate that only Canadian importers can currently qualify for CTPAT validation as foreign IORs. In practice, most foreign IORs will need a validated broker.
- Informal entries (generally shipments valued at $2,500 or less) follow the same CTPAT or validated-broker rule for now. The EO directs CBP to bar foreign IORs from informal entry outright, and CBP has said it may do so if the safeguard proves insufficient.
- Continuous bonds: the EO says foreign IORs filing formal entries should not rely on a continuous bond unless CBP determines revenue is fully protected.
- A broker that is not CTPAT-validated and finds a client is not a U.S. IOR must stop filing for that client. Only a minority of licensed brokers are CTPAT-validated.
- A power of attorney is required whenever a broker transacts customs business for a client, including when the broker acts as the importer.
If you are a U.S. buyer, check who is the importer of record on your inbound shipments. If a foreign supplier, marketplace, or logistics provider acts as IOR (common in DDP deals), your supply may stop on January 5, 2027 unless that party is validated or uses a validated broker.
Key Dates
| Date | Event |
|---|---|
| June 3, 2026 | EO 14411 signed (published June 10, 2026) |
| August 19, 2026 | CBP notice on Form 5106 accuracy published (91 FR 53627) |
| September 1, 2026 | 90-day mark in the EO: penalty-mitigation standards, expedited disposal, transparency measures, foreign exporter documents |
| September 2, 2026 | CBP advance notice on Heightened Import Disclosures published (91 FR 56408) |
| September 18, 2026 | CBP begins voiding IOR numbers with inaccurate Form 5106 data |
| November 6, 2026 | Interim final rule on foreign IORs published |
| November 30, 2026 | 180-day mark in the EO: IOR eligibility revisions, good standing, registry update, enhanced vetting |
| December 1, 2026 | Comment deadline, Heightened Import Disclosures advance notice (Docket USCBP-2026-1058) |
| January 5, 2027 | Foreign IOR rule takes effect; comments due (Docket USCBP-2026-1387); last day for brokers to request delayed compliance with client verification |
| May 6, 2027 | Outside date for full broker compliance |
| June 3, 2027 | One-year effectiveness report due to the President |
Tougher Enforcement and Penalties
- The EO directs a penalty-mitigation floor of at least 50% of the assessed penalty, no mitigation for repeat offenders, and a minimum floor for liquidated damages.
- It directs maximum penalties for brokers who fail due diligence, repeatedly represent noncompliant clients, or are slow to cooperate with CBP.
- The interim final rule broadens CBP’s ability to assess 19 U.S.C. 1592 penalties against brokers, with the maximum set at the domestic value of the merchandise. Before, the cap was $30,000.
- Forced labor, misclassification, undervaluation, and illegal transshipment are named enforcement priorities.
What to Do Now
- Audit your CBP Form 5106. Fix the physical address, email, phone, and ownership data before CBP does it for you.
- Test your status. Check whether each importing entity meets the U.S. IOR definition, including beneficial ownership and U.S. location. Gather the records.
- Map your IOR structure. Find every entry where a foreign party is the importer of record, including DDP and marketplace shipments.
- Ask your broker in writing: Is it CTPAT-validated? Has it requested delayed compliance? What records will it need from you?
- Review your bond and domestic assets. Minimum asset and bonding requirements are coming.
- Prepare your supply-chain data. Manufacturer, exporter, and production details will matter more.
- Comment if it affects you. Both comment windows are short.
How Navco Helps
Navco is a CTPAT-validated U.S. Customs broker with a national permit, so foreign importers of record can enter goods through Navco after January 5, 2027, and U.S. importers get a broker that is built for the new rules.
- Entry filing for foreign IORs through a CTPAT-validated broker.
- IOR readiness review: U.S. IOR status, Form 5106 accuracy, ownership documentation, and power-of-attorney setup.
- Supply-chain and IOR mapping to find where a foreign supplier or marketplace is the importer today, and fix it before the deadline.
- Bond and continuous-bond review.
- Disclosure readiness: manufacturer, exporter, and production data organized for the heightened disclosures CBP is considering.
- Bonded and in-bond programs that give you more control over when and where duties are paid.
- Border logistics: warehousing, transportation, and cross-border handling in Brownsville, Los Indios, and across the Texas border.
One team handles the filing, the compliance, and the freight. To talk through your situation, see Navco’s customs brokerage services and Trade & Logistics Advisory, or contact Navco.
Frequently Asked Questions
What is Executive Order 14411?
Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026, directs DHS and CBP to tighten importer-of-record eligibility, require more disclosure, restrict foreign importers of record, and increase penalties and enforcement.
Who is a foreign importer of record?
Any importer of record that is not a “U.S. IOR.” A U.S. IOR is a U.S. citizen or lawful permanent resident, or an entity organized under U.S. law, located in the U.S., that is at least 51% controlled by U.S. citizens or lawful permanent residents or directly owns a significant amount of unencumbered U.S. real property.
When do the new foreign IOR requirements start?
January 5, 2027. Comments on the interim final rule are due the same day.
What must a foreign importer of record do?
Be CTPAT-validated, or use a CTPAT-validated licensed customs broker, to enter goods for consumption. Only Canadian importers can currently qualify for validation as foreign IORs, so most foreign IORs will need a validated broker.
Do U.S. importers of record need CTPAT validation?
No. U.S. IORs may use a broker that is not CTPAT-validated, but they must declare their U.S. IOR status on entries and the broker must verify it.
What happens if my CBP Form 5106 information is inaccurate?
CBP can void your IOR number. A voided number is invalid for any purpose, including entering goods. CBP began doing this on September 18, 2026.
Can foreign importers still file informal entries?
For now, yes, if they are CTPAT-validated or use a CTPAT-validated broker. CBP has said it may bar foreign IORs from informal entry entirely.
How can Navco help?
Navco is a CTPAT-validated customs broker. We can file entries for foreign importers of record, review U.S. IOR status and Form 5106 data, map your IOR structure, and prepare your supply-chain data for the new disclosure rules.
This article summarizes Executive Order 14411 (91 FR 35125), CBP’s notices at 91 FR 53627 and 91 FR 56408, and CBP’s interim final rule on foreign importers of record (Federal Register Doc. 2026-22735), current as of November 10, 2026. The rule is interim and open to comment; CBP guidance may change. This is general information, not legal advice. Verify current requirements with CBP or your customs broker before relying on this summary for a specific entry or structure.
Sources:Executive Order 14411 (Federal Register Doc. 2026-11595) · CBP, Accuracy of Importer of Record Data, 91 FR 53627 · CBP, Heightened Import Disclosures, 91 FR 56408 · CBP, Heightened Requirements for Foreign Importers of Record (Doc. 2026-22735) · Troutman Pepper Locke · Thompson Hine · Sandler, Travis & Rosenberg · Diaz Trade Law · National Law Review