Executive Order 14411: the new US rules for foreign importers of record.

The order in five lines

What EO 14411 means for a brand that imports into the US

• Executive Order 14411, “Strengthening Customs Enforcement”, was signed on 3 June 2026 and published on 10 June.
• The order tells US Customs and Border Protection (CBP) to bar foreign importers of record from informal entries, the simpler entry type used for low-value shipments.
• For formal entries, a foreign importer of record will need CBP's agreement to use a continuous bond, and must be validated in CTPAT (CBP's supply-chain security program) where eligible, or file through a CTPAT-validated licensed customs broker.
• Every importer of record will face higher bond or US-asset minimums and wider disclosures. Most of these changes are due within 180 days, so about 30 November 2026.
• Since 18 September 2026, CBP has been voiding importer numbers whose CBP Form 5106 data is inaccurate or incomplete.

What changed, and when

The dates so far

1. 29 Aug 2025Duty-free treatment of low-value parcels (de minimis) is suspended for goods from every country.Executive Order 14324 · Federal Register
2. 3 Jun 2026EO 14411 is signed. It is published on 10 June (91 FR 35125).Federal Register
3. ≈18 Jul 2026The 45-day mark: recommendations to the President for customs legislation.EO 14411, sec. 8
4. 19 Aug 2026CBP's first implementing notice: it will check the identity data importers of record give on CBP Form 5106.Federal Register notice 2026-16911
5. ≈1 Sep 2026The 90-day mark: steps on foreign export documents, minimum penalty floors, disposal of non-compliant imports and transparency.EO 14411, secs. 3–6
6. 2 Sep 2026CBP asks for comments on heightened import disclosures for supply-chain visibility, open until 1 December 2026.Federal Register 2026-17926
7. From 18 Sep 2026CBP voids importer numbers whose Form 5106 data is inaccurate or incomplete.Federal Register notice 2026-16911
8. 8 Oct 2026CBP proposes new rules for low-value shipments, including bonding requirements for certain informal entries. Comments are open until 7 December 2026.Federal Register 2026-20650
9. ≈30 Nov 2026The 180-day mark: the deadline to revise importer eligibility rules, define “good standing”, clean up the importer registry and set up enhanced vetting.EO 14411, sec. 2

When this guide was updated, CBP had not published final rules for foreign importers of record, so the 180-day date is expected, not fixed. Some parts of the order (the informal-entry ban, the bond and CTPAT conditions) are to be issued “promptly”, with no set date.

What the order says

The clauses that reach foreign brands

Section 10

Who counts as a foreign importer of record

A company is a US importer of record if it meets all three tests below, or if it owns a significant amount of real property in the US, as DHS decides. Anything else is foreign.

So the order may reach:

• brands abroad that import in their own name, with no US company (CBP calls these non-resident importers);
• sellers shipping parcels to US customers duty-paid (DDP), through marketplaces or direct to consumer;
• US companies controlled from abroad without real US operations or assets. The order tells DHS to stop shell companies and artificial structures from qualifying as US.

Your options

Three ways to keep importing

Pick3PL is not a customs broker and does not file entries. We introduce you to the preferred partner, which imports through its licensed broker. See how the importer-of-record service works.

Before about 30 November

What to do this month

1. Find out who your importer of record is.On every shipment, not just the last one. Ask your forwarder or courier if you're not sure.
2. Check your Form 5106 data.The physical address must be your real business location, not a forwarder, registered agent or PO box. Inaccurate data can void your importer number.
3. Test your company against Section 10.Where it's organized, where it's located, who controls it, and what it owns in the US.
4. Ask your customs broker two questions.Is it CTPAT-validated, and how will it vet foreign importer clients?
5. Review your bond with your broker or surety.Type and coverage, before the higher minimums arrive.
6. If you ship low-value parcels, plan the change.Without informal entries, parcels need formal entries, or stock landed in the US before it's sold.
7. Pick your route and set a date.Qualify, use a US importer of record, or sell to a US importer. Check CBP's “Strengthening Customs Enforcement” page for new notices.

Sources

Where this comes from

1. Executive Order 14411, “Strengthening Customs Enforcement”, Federal Register 2026-11595, 91 FR 35125, 10 June 2026.
2. CBP, “Accuracy of Importer of Record Data Submitted to CBP”, Federal Register 2026-16911, 19 August 2026.
3. CBP, “Heightened Import Disclosures for Supply Chain Visibility”, Federal Register 2026-17926, 2 September 2026.
4. CBP, “Low-Value Shipments”, proposed rule, Federal Register 2026-20650, 8 October 2026.
5. CBP, “Strengthening Customs Enforcement”, last modified 15 October 2026.
6. Executive Order 14324, “Suspending Duty-Free De Minimis Treatment for All Countries”, Federal Register 2025-14897, 5 August 2025.
7. RSM US, “Executive Order 14411 tightens rules for foreign importers of record”, 15 July 2026.

Checked 23 October 2026. CBP had not published its final rules for foreign importers of record, so all timing is expected and approximate.This is general information, not legal advice.