Executive Order 14411 and Strengthening Customs Enforcement
What importers need to know about current CBP actions and proposed changes
Last reviewed October 16, 2026
Executive Order (EO) 14411, signed June 3, 2026, directs the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to strengthen customs enforcement. Its priorities include verifying who acts as an importer of record (IOR), protecting the collection of duties, gaining better visibility into imported goods and their supply chains, and addressing customs violations.
CBP is implementing the order in stages. Some actions already affect importer numbers and entry filings. Other changes, including broader supply chain disclosures, are still being considered. This guide separates what is happening now from what may come next.
What Does Executive Order 14411 Cover?
The order directs DHS and CBP to examine and update several parts of the import process:
- Importer eligibility and identity. CBP is directed to review the information used to identify IORs, update its importer registry, establish enhanced vetting, and define what it means for an IOR to remain in good standing.
- Bonds and financial safeguards. The order calls for revised requirements concerning bond coverage, tangible domestic assets, or both. It does not itself announce a new bond amount that every importer must obtain today.
- Foreign IORs. The order directs CBP to address foreign IORs’ use of informal entry, their bond arrangements for formal entry, and the potential role of Customs Trade Partnership Against Terrorism (CTPAT) validation or a CTPAT-validated customs broker.
- Import and supply chain information. CBP is directed to pursue more detailed disclosures about the parties and goods involved in an import and to examine documentation submitted to foreign customs authorities.
- Enforcement. The order calls for greater attention to matters including forced labor, misclassification, undervaluation, illegal transshipment, audits, penalties, and liquidated damages.
These are directions to agencies, not a single set of requirements that all took effect on June 3. The applicable CBP notice, guidance, regulation, or system change determines how a particular measure works and when it applies.
What Has CBP Implemented?
Inactive Importer Numbers
On July 16, 2026, CBP introduced an “Inactive for Entry Purposes” status in the Automated Commercial Environment (ACE). An IOR that has not filed an entry within 366 days can be placed in that status. The IOR then cannot transmit ACE Cargo Release or Entry Summary transactions until the number is reactivated.
This status does not disable every ACE activity. CBP says it does not prevent an IOR from acting as a consignee, filing drawback claims or reconciliations, securing bonds, or transmitting Importer Security Filing information. Importers that file infrequently should check their IOR status with their customs broker before their next shipment needs to be entered. CBP has provided electronic and manual reactivation procedures.
Accuracy of Form 5106 Information
CBP is also reviewing Form 5106 information for new and existing IORs. Beginning September 18, 2026, CBP said it would immediately void an IOR number if the information provided is inaccurate or incomplete, preventing the number from being used to enter merchandise.
Importers should ensure their physical address, email, and telephone number are accurate and belong to the IOR—not a broker, freight forwarder, registered agent, or other third party. Brokers submitting Form 5106 must also have a valid power of attorney directly with the IOR. If a number is voided, CBP will notify the IOR and explain how to request reestablishment. This is separate from inactive-for-entry status for unused numbers.
What is Developing for Foreign IORs and Brokers?
EO 14411 directs CBP to revise policies affecting foreign IORs. In an August 2026 CTPAT alert, CBP also described heightened expectations it plans to apply to CTPAT-validated customs brokers representing foreign IORs.
The alert says those brokers will need to conduct more extensive vetting of foreign clients. It identifies the IOR’s legal identity, ownership, affiliations, U.S. assets, compliance history, and ability to pay customs liabilities among the subjects to review. It also addresses verification of shipment details and retention of vetting records, powers of attorney, and relevant communications.
The alert describes these as upcoming expectations and says CBP will take steps to revise importer eligibility regulations, guidance, and policies. Importers and brokers should monitor those steps before treating every provision described in the order or alert as a fully implemented filing rule. Read CBP’s CTPAT alert.
What Supply Chain Disclosures is CBP Considering?
On September 2, 2026, CBP published an advance notice of proposed rulemaking on heightened import disclosures and supply chain visibility. CBP is seeking input on questions such as:
- Whether importers should submit or retain documents their exporters provided to foreign customs authorities.
- How CBP could better identify manufacturers, shippers, exporters, sellers, and other parties in an import transaction.
- Whether additional business or product identifiers could improve visibility.
- How supply chain tracing technology might be used, including within CTPAT.
- What these approaches would cost and how they would affect small businesses and the movement of critical goods.
This notice asks for feedback; it does not require every importer to submit a foreign export declaration with every entry now. CBP is still considering whether documents would be transmitted with an entry, retained for later production, or handled another way. Comments are due December 1, 2026.
Who Should Pay Attention?
All importers of record should confirm that their Form 5106 information is complete and accurate. Importers that ship infrequently should also check whether their IOR number remains active for entry.
Foreign IORs and the brokers representing them should watch for further guidance on importer eligibility, entry procedures, bonds, CTPAT, and broker vetting. Importers with multiple suppliers or intermediaries should consider who holds the export and production records that CBP may seek under a future disclosure rule.
What Should Importers Do Now?
Check the Form 5106 record.
Confirm the legal identity, identification number, actual physical address, email address, and telephone number. Coordinate any necessary correction with your customs broker.
Check IOR status before the next entry.
This matters especially if the number has not been used for roughly a year. Allow time for reactivation if needed.
Know where the supporting records are.
Identify the parties that hold export declarations, invoices, product details, origin support, and other supply chain records. Being able to locate them now will make it easier to respond to CBP inquiries or future requirements.
Review entry data for consistency.
Confirm that classification, value, origin, manufacturer details, and supporting records are accurate. Investigate differences among records before they become an issue in a CBP review.
Consider commenting on the disclosure proposal.
Companies with practical insight into access to foreign export records, timing, technology, costs, or small-business effects can submit comments by December 1, 2026.
Implementation Timeline
While the Executive Order establishes policy direction, implementation will occur over time through regulatory action.
Seeking Comments
Enforcement Begins
Upcoming Expectations
In Effect
CBP Guidance
Order Signed
Frequently Asked Questions
No. The order directs DHS and CBP to take a range of actions. CBP has since implemented certain importer-number measures, while broader changes are still being developed or considered. The status of each measure depends on the subsequent CBP action.
An inactive-for-entry status can follow a period without entry filings and has a CBP reactivation process. Voiding under CBP’s Form 5106 initiative concerns information CBP determines is inaccurate or incomplete; CBP says its notice will explain how to request reestablishment. Both can interrupt entry filings, but they arise for different reasons and have different procedures.
Possibly. The Executive Order instructs CBP to review current bond requirements and consider whether additional financial protections are necessary. Any specific changes would be announced through future regulations.
The September 2 notice does not create that general requirement. CBP is asking whether and how foreign export documentation should be submitted or retained. Comments on that question are due December 1, 2026.
EO 14411 directs CBP to review foreign importer eligibility, customs bond arrangements, and entry procedures. CBP has also outlined heightened vetting expectations for CTPAT-validated customs brokers representing foreign IORs, including verification of importer identity, ownership, financial resources, and compliance history.
These measures are being developed through CBP guidance and regulatory action. Importers and brokers should monitor official announcements rather than assume every proposed requirement is already in effect.
Official Sources
- Executive Order 14411 (White House)
- Strengthening Customs Enforcement resrouce hub (CBP)
- CSMS #69056621: Reactivating a deactivated IOR (CBP)
- CSMS #69241265: "Inactive for Entry Purposes" status (CBP)
- Accuracy of Importer of Record Data Submitted to CBP (Federal Register)
- CTPAT Alert for Broker Responsibilities Under Executive Order 14411 (CBP)
- Heightened Import Disclosures for Supply Chain Visibility (Federal Register)
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