For importers, this is likely to result in increased scrutiny, possible disruption to non-resident IOR models, more evidence requirements, and a need to review US import arrangements.
This article outlines the key dates and changes, and steps that importers can take to get prepared.
| Date | Milestone | What it means |
| 3 June 2026 | Executive Order signed | Starting date for the Order’s 45, 90, 180 day, and one-year deadlines. |
| 18 July 2026 | 45 days from the Order | The 45-day requirement is not a regulatory implementation deadline for importers, IORs, or customs brokers. Instead, it is an internal U.S. government deadline to develop and submit proposed legislative changes to Congress or the President aimed at further strengthening customs enforcement. |
| 1 Sept 2026 | 90 days from the Order | Target date for action on exporter documentation, penalty-mitigation standards, disposal of non-compliant goods, and transparency measures. The Order generally says “take steps” so this should not be presented as a single commencement date for every new requirement. |
|
30 Nov 2026 |
180 days from the Order | Target for revised IOR eligibility measures, good-standing rules, registry updates, risk tiers, and enhanced recurrent vetting. |
| 3 June 2027 | One year from the Order | Deadline for DHS to report to the President on the effectiveness of the measures. |
Summary of key changes
- Stricter IOR eligibility requirements Importers of Record (IORs) will face enhanced vetting, including minimum US asset and/or bonding requirements, plus greater disclosure of ownership, affiliations, import volumes and financial standing.
- Greater scrutiny of foreign IORs CBP will distinguish more clearly between US and foreign IORs. Having a US address or incorporation alone may no longer be sufficient; companies will need to demonstrate genuine US operations, assets and business substance.
- Restriction on informal entries Foreign IORs are expected to be prohibited from using informal entry procedures for lower-value shipments, potentially requiring a move to formal entries or a US-based IOR model.
- Tighter rules for formal entries Foreign IORs will face additional compliance requirements for formal entries and may no longer be able to rely on continuous customs bonds unless specifically approved by CBP. Existing bond and broker arrangements should be reviewed.
At the same time, lawmakers have introduced the proposed Securing Accountability in Foreign Entries (SAFE) Act, which could significantly alter the way non-resident importers operate in the United States. If enacted, the legislation would introduce additional eligibility requirements and a stronger U.S. nexus for entities acting as Importers of Record. However, the bill has not yet become law, and implementation would be subject to future regulations and transition periods.
What does this mean for non-resident importers?
Many international companies have historically relied on non-resident importer arrangements to access the U.S. market. While that model remains available today, proposed reforms suggest that additional requirements may apply in the future, potentially increasing administrative burdens and compliance obligations for overseas businesses.
For businesses without a U.S. establishment, maintaining compliance may become increasingly complex as requirements evolve.
That is why many organisations are now evaluating alternative approaches that provide greater certainty and long-term stability.
What should you do now to get prepared?
There are currently no confirmed dates on which the proposed changes will take effect. We are closely monitoring developments while continuing to operate under the existing CBP framework. Early planning gives businesses time to identify exposure, gather evidence, and consider alternative IOR arrangements before requirements change. Whilst we await an effective date, here are some steps to get prepared:
Although the exact timing and scope of U.S. Importer of Record reforms remain subject to ongoing rulemaking and legislative developments, the message from regulators is clear: importer accountability will continue to be a major area of focus.
Until final guidance is published, businesses should continue to prioritise compliance and ensure that their import structures are capable of adapting to future requirements.
How can we help?
Using our many years of experience as a US Importer of Record we can provide a compliant IOR solution into the US for non-resident importers. By using our services, it will provide you with comfort that you can carry on importing your goods into the US in an ever-changing environment. Our experienced team helps to provide a reliable and compliant pathway into US markets both today and in the future.
Get in touch if you have any questions or wish to discuss your future IOR strategy.
This article is based on publicly available information as at the date of publication. The Executive Order, proposed legislation and associated rulemaking remain subject to further clarification, change and implementation guidance.
