Breaking! Trump signs an executive order! The U.S. import customs clearance market faces a major reshuffle

According to a White House announcement, President Trump signed a major comprehensive executive order called "Strengthening Customs Enforcement" on June 4 local time. These changes will have significant operational and compliance impacts on all importers—especially offshore entities acting as "Importers of Record" (IOR).

**Key Terms Affecting Importers**

**A. Stricter requirements for all "Importers of Record" (IOR)**
 

• All IORs must maintain a minimum amount of onshore tangible assets and/or provide higher guarantees as determined by U.S. Customs and Border Protection (CBP).
• Required enhanced data disclosure, including: estimated import volume, year of establishment, ownership and ultimate beneficiary details, business related-party relationships, and domestic asset status.
• All IORs must maintain a "Good Standing" status with CBP based on their compliance record.
• Stricter scrutiny (including regular reviews) of IORs, customs brokers, freight forwarders, and other entities involved in import business.
• Importers must submit relevant documents previously submitted by the foreign exporter to their own customs authorities.

**B. Major Restrictions Targeting Overseas "Record Importers"**

This executive order clearly distinguishes between IORs within the United States and those outside the United States. These changes reflect the challenges CBP faces in enforcing operations against foreign entities.
• Prohibition on foreign IORs from submitting informal customs declarations (i.e., low-value goods declarations as stipulated in Article 321).
• For formal declarations, foreign IORs generally cannot use a "Continuous Bond" and are only allowed in very rare cases—i.e., when CBP confirms they have provided sufficient tax protection and meet compliance requirements.
• Overseas IORS must be certified by the Customs-Trade Counterterrorism Alliance (CTPAT), or be authorized to act as agents by a licensed customs broker that has passed CTPAT certification.

**Schedule Highlights**
 

• Multiple new regulations must be implemented within 90 or 180 days.
• U.S. domestic "recorded importers" with a solid physical foundation and a strong compliance record will be in the most advantageous position.

In the face of the current new normal of rapidly changing trade policies that often lack prior notice, any importer operating alone may find themselves at a disadvantage in terms of compliance and timeliness. This is exactly where we—a professional team rooted in China for 15 years, deeply engaged in the international logistics field—can help you mitigate risks and create certainty.