Trump Signs Order to Tighten U.S. Customs Enforcement (Process to Reactivate IORs Now Available)
Trade Update • June 4, 2026 | Updated June 27, 2026
Key Points
- Foreign importers of record (IORs) are barred from filing informal entries and face stricter bonding and compliance requirements for formal entries.
- All IORs must maintain “good standing” with CBP; those tied to fentanyl, contraband, or customs violations lose import privileges entirely.
- Penalty minimums are set at 50% of the assessed amount, with no mitigation for repeat offenders.
- Importers must now disclose supply chain details, foreign tax identifiers, and certify compliance with forced labor and sanctions laws.
- DHS has 180 days to overhaul the IOR registry, introduce risk-based tiering, and strengthen vetting of brokers, freight forwarders, and custodians.
- Latest: CBP is deactivating IOR numbers in ACE that haven’t filed an entry for one or more years and have no outstanding post-entry transactions; deactivated numbers can be reactivated through an ABI broker or by submitting a revised CBF 5106 for manual reactivation.
President Trump signed an executive order on June 3, 2026, directing a comprehensive reform of U.S. customs enforcement. The order addresses longstanding gaps that have allowed importers to undervalue goods, conceal ownership, and avoid duty payments. CBP is directed to raise bonding requirements, tighten importer eligibility, expand disclosures, and accelerate disposal of non-compliant imports. Per the accompanying White House fact sheet, these reforms will not take effect immediately. Department of Homeland Security (DHS) and CBP will go through the standard rulemaking process, giving affected parties time to adjust operations.
June 26 Update: CBP has already started deactivating IOR numbers in ACE that haven’t been used to file an entry for one or more years and have no outstanding post-entry transactions; affected importers can reactivate them through the process outlined below.
Importer of Record (IOR) Reforms
Eligibility and Bonding
- IORs must maintain minimum domestic assets and/or bonding at all times
- Minimum bond coverage requirements will increase
- Foreign IORs are prohibited from filing informal entries 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 to file entries with CBP
Disclosure Requirements
- IORs must report anticipated import volumes, ownership and beneficial ownership, business affiliations, and domestic assets to CBP
- Detailed supply chain information required, including manufacturer identifiers, product specs, composition, and grade
- Export documentation submitted to the origin country’s customs authority must also be filed with CBP
Good Standing and Registry
- CBP will define “good standing” based on compliance history, affiliated entities, and payment of customs liabilities
- IORs linked to fentanyl, nitazenes, or contraband are automatically disqualified
- The IOR registry will be updated to remove inactive records, confirm compliance, and tier importers by risk level
Enforcement
- Penalty floor set at 50% of the assessed penalty, with exceptions only in narrow national security circumstances
- A minimum liquidated damages floor will be established
- No penalty mitigation for repeat offenders
- Customs brokers face maximum penalties for failing due diligence, repeatedly representing non-compliant clients, or not cooperating with CBP inquiries
- DHS and the DOJ are directed to prioritize forced labor violations, misclassification, undervaluation, and illegal transshipment cases
Transparency and Disposal
- CBP must publish annual enforcement transparency reports
- Confidentiality requests will be subject to periodic review and expiration
- Seizure and disposal of non-compliant imports will be expedited, including authorization of third-party disposal
Key Deadlines
- 45 days: DHS submits legislative recommendations to the President
- 90 days: Revised penalty standards, new disclosure rules, disposal procedures, and transparency measures in place
- 180 days: Updated IOR eligibility rules, good standing requirements, enhanced vetting, and registry overhaul completed
- 1 year: DHS submits effectiveness report to the President
Latest: Process to Re-Activate a Deactivated IOR
On June 26, 2026, CBP announced that, under the aforementioned Executive Order, it is deactivating IOR numbers that:
- Have not been used to file an entry for one or more years
- Have no outstanding post-entry transactions.
Importers seeking to reactivate their IOR numbers are advised to work closely with their customs broker to avoid potential delays in processing.
Through an ABI broker
An ABI broker submits a Transaction Processing (TP) message with Action Code A to change the status from “20-Inactive” to “10-Active.” All required CBF 5106 data elements must be submitted with the TP message.
Manual Reactivation
Importers who can’t reactivate via ABI may submit a revised CBF 5106, with all mandatory data elements completed, to a Center Entry Specialist Team. The email must include “IOR reactivation request” in the subject line and explain in the body that the CBF 5106 is being submitted to reactivate an IOR that already exists but is currently in “20 – Inactive” status. Reactivation timing depends on the Center’s workload.
Before contacting CBP
Query and verify the IOR’s current status in the ACE Portal Account first.
Meanwhile, FAQs and other resources can be found on the CBP Form 5106 page at cbp.gov. For questions about CBF 5106, reach out to IORProgram@cbp.dhs.gov.
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