While many of the changes will be introduced through formal rulemaking over the coming months, the direction of trade is clear: importing into the U.S. is becoming increasingly dependent on demonstrable compliance, transparency, and financial responsibility.

At the heart of the Executive Order is a strengthened approach to Importer of Record (IOR) eligibility. CBP has been instructed to revise importer requirements to include greater evidence of U.S.-based assets or increased bond coverage, alongside expanded disclosures relating to ownership structures, affiliations, and operational activities. Businesses operating through importer structures that lack a meaningful U.S. presence or sufficient financial backing may face increased scrutiny and, potentially, challenges to their eligibility.

The reforms also create a clearer distinction between domestic and foreign Importers of Record. Foreign IORs will face additional restrictions, including limitations on the use of informal entry procedures commonly associated with low-value shipments. Additional compliance validation requirements for formal entries are also expected. These changes are likely to have a significant impact on non-resident importers, e-commerce businesses, direct-to-consumer supply chains, and organisations that rely heavily on low-value import programmes.

Another major development is the introduction of a formal "good standing" requirement. CBP will assess importers based on factors such as compliance history, duty payment performance, and involvement in customs violations, including misclassification, undervaluation, and forced labour-related infractions. Importers that fail to meet these standards could ultimately lose the ability to import goods into the United States. This represents a fundamental shift in policy, reinforcing the view that importing is increasingly being treated as a privilege earned through ongoing compliance rather than a routine administrative process.

The Executive Order also signals a move towards greater supply chain transparency. Importers will be expected to provide more detailed information regarding ownership structures, production methods, product identifiers, and certifications confirming compliance with applicable customs and trade regulations. These requirements reflect CBP's growing focus on traceability and visibility across global supply chains and will likely require businesses to strengthen data collection and record-keeping practices.

Enforcement measures are also set to become significantly more stringent. The Order directs CBP to establish a minimum penalty floor of 50% for violations and reduce opportunities for mitigation, particularly for repeat offenders. Businesses should also anticipate an increase in audits, investigations, and enforcement actions as regulators seek to strengthen oversight and protect revenue collection. As a result, the financial consequences of non-compliance are expected to increase materially.

In addition, CBP will receive enhanced authority to manage non-compliant shipments through streamlined seizure procedures, expanded voluntary abandonment options, and the ability to facilitate third-party disposal of goods. For importers, this could result in faster cargo losses and greater financial exposure where compliance failures occur.

The stated objective of the reforms is to address concerns around duty evasion, undervaluation, misclassification, opaque importer structures, and the importation of prohibited or forced labour-linked goods. As stated by CBP leadership, "Importing into the U.S. has for too long been treated as a right and not a privilege." Collectively, the measures reinforce CBP's intention to place compliance and accountability at the centre of U.S. import operations.

What Importers Should Do Now

Although implementation will occur through formal rulemaking over the next 90 to 180 days, organisations should begin preparing now.

Immediate priorities should include:

• Reviewing Importer of Record structures, particularly where foreign or non-resident importer arrangements are used
• Assessing customs bond sufficiency and financial capacity
• Conducting compliance reviews covering tariff classification, valuation, and country of origin declarations
• Evaluating supply chain transparency and traceability capabilities
• Strengthening internal customs compliance controls and audit readiness processes
• Reviewing customs broker relationships and due diligence procedures

Businesses that take proactive steps today will be better positioned to adapt as the regulatory framework develops and avoid disruption once the new requirements are implemented.

Woodland Group Insight

While the Executive Order itself does not immediately change existing customs regulations, it provides a clear indication of CBP's future enforcement priorities. The direction of trade is unmistakable: greater scrutiny, greater accountability, and greater expectations around supply chain visibility.

For organisations importing into the United States, this is likely to represent a long-term shift rather than a temporary enforcement initiative. Companies that invest now in compliance readiness, importer governance, and supply chain transparency will be in a stronger position to minimise risk, maintain operational continuity, and protect access to the U.S. market.

Preparing for the Changes?

The new U.S. customs enforcement framework is expected to introduce significant compliance obligations for importers, non-resident importers, and e-commerce businesses.

Woodland Group's customs and trade specialists can help you assess your importer structure, review compliance processes, and prepare for upcoming regulatory requirements.