U.S. Customs Rules: What Changes?
- Annkaren Wambui

- 1 day ago
- 4 min read
🔓Stay informed on US Customs Rules: What Changes? Discover key updates impacting foreign Importers of Record and compliance strategies. Read more on US Import Rules: What Changes?
The new Executive Order on Strengthening Customs Enforcement introduces tighter requirements for foreign Importers of Record, expanded disclosure obligations, and tougher penalties. Businesses relying on DDP models, informal entries, or continuous bonds should understand how the changes could affect U.S. market access and compliance responsibilities. |
Why Are U.S. Import Rules Changing?

The United States has announced a major package of customs reforms aimed at strengthening enforcement and protecting customs revenue.
The new measures target issues including forced labour, undervaluation, illegal transshipment and weak importer accountability.
For many businesses, customs compliance is increasingly becoming a strategic issue rather than simply an operational requirement.
What Happens to Foreign Importers of Record?

One of the biggest changes concerns foreign Importers of Record.
Within 180 days, foreign IORs will no longer be permitted to file informal entries. Access to continuous bonds for formal entries may also become more restricted unless Customs and Border Protection determines that revenue is adequately protected.
Foreign Importers of Record may also need CTPAT validation or support from a CTPAT-validated broker.
For many UK and EU businesses currently acting as their own Importer of Record, the changes could require a review of existing structures.
Why Could Marketplace Models Be Affected?

The new rules place greater emphasis on beneficial ownership and supply chain transparency.
Businesses operating through B2B2C models or marketplace structures may need to reassess their arrangements and determine whether U.S. entities satisfy the new "good standing" expectations.
Detailed disclosure requirements relating to ownership, tax identifiers, production data and supply chain information are expected to become increasingly important.
For some organizations, the biggest challenge may not be tariffs but transparency.
Enforcement Priorities Are Expanding

The Executive Order places particular emphasis on:
► Forced labor
► Misclassification
► Undervaluation
► Illegal transshipment
► Revenue protection
The measures also reference EAPA investigations and cooperation with the Department of Justice, signaling a tougher enforcement environment.
Repeat offenders could face substantially higher penalties and reduced opportunities for mitigation.
What Does This Mean for UK and EU Exporters?

Businesses selling DDP into the United States or relying on foreign IOR structures should not wait until the final implementation date.
Companies may wish to:
► Review Importer of Record arrangements
► Assess customs bond requirements
► Strengthen supply chain documentation
► Evaluate marketplace and B2B2C structures
► Improve due diligence and customs controls
► Prepare for increasing disclosure requirements
Businesses that prepare early may be better positioned to maintain access to the U.S. market and reduce customs risks.
Final Thoughts
The new Executive Order represents a major shift in how the United States approaches customs enforcement and Importer of Record accountability.
While the changes are designed to combat fraud and protect revenue, they could have significant consequences for UK and EU exporters relying on existing import structures.
Success will increasingly depend on a company's ability to understand its supply chain, strengthen documentation and maintain effective compliance controls.
The key takeaway?
Accountability matters.
Businesses that review their Importer of Record arrangements, improve transparency and proactively assess compliance risks will be best positioned to maintain access to the U.S. market while reducing customs and enforcement risks.
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Related Topics
#ImporterOfRecord #CustomsEnforcement #CBP #TradeCompliance #CustomsCompliance #UKExporters #EUExporters #SupplyChain #InternationalTrade #CTPAT #EAPA #USImports
Author:
Annkaren Wambui | Growth Partner at Customs Manager Ltd.
Updated: June 2026
Disclaimer
This blog is for informational purposes only and does not constitute legal or professional advice. Please consult a customs specialist regarding your specific compliance obligations.




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