U.S. Customs and Border Protection (CBP) is increasing its scrutiny of importer identity, eligibility, and financial accountability. Recent federal actions introduce additional requirements for foreign Importers of Record (IORs) and reinforce the importance of accurate importer registration information.
These developments may affect foreign suppliers using their own IOR numbers for Delivered Duty Paid (DDP) shipments, as well as U.S. buyers importing under Delivered at Place (DAP) terms.
Key Developments
Executive Order 14411 – Foreign Importer Requirements
Signed June 3, 2026, Executive Order 14411 directs the Department of Homeland Security (DHS) and CBP to strengthen foreign importer eligibility and oversight.
The proposed changes include additional ownership disclosures, higher bond requirements, CTPAT-related conditions, restrictions on continuous customs bonds and informal entries, and recurring importer eligibility reviews.
Implementation depends on further agency action. Not all directed restrictions are currently in effect.
CBP Form 5106 Enforcement – Importer Verification
Effective September 18, 2026, CBP began reviewing new and existing importer registration records.
Importer of Record numbers may be voided when required information is inaccurate, incomplete, or not directly associated with the importer. This includes business addresses and contact information, as well as requirements for direct customs broker authorization.
Important Date
November 30, 2026: Upcoming agency action milestone under Executive Order 14411. This milestone directs further agency action and does not automatically activate every foreign importer restriction.
What Importers Should Know
These developments make it increasingly important for U.S. buyers and foreign suppliers to understand their respective customs responsibilities, verify the actual Importer of Record, and ensure importer registration and broker authorization information is accurate.
The distinction between DAP and DDP shipments is particularly important, as contractual delivery terms do not independently determine the legal Importer of Record or eliminate potential customs exposure.
Juno Customs Solutions has prepared a detailed guide covering the new requirements, the differences between DAP and DDP responsibilities, potential operational impacts, and five important checks U.S. importers should complete before their next shipment.
For questions about how these developments may affect your imports, contact the Juno Customs Solutions team.