Preparing for the Next Wave of Customs Enforcement

Customs enforcement is entering a new phase-one that will require importers to provide stronger records, greater supply chain visibility, and more complete data to support their compliance obligations. After several years of new tariffs, trade remedies, antidumping and countervailing duties, and measures under the International Emergency Economic Powers Act, shippers are now facing a broader push toward importer accountability.

This blog outlines what has changed, what enforcement actions may be coming next, and practical steps importers can take now to reduce risk and prepare for increased scrutiny.

What we've seen so far

As global supply chains become more complex and enforcement priorities continue to evolve, U.S. Customs and Border Protection (CBP) is increasing its focus on importer accountability, supply chain visibility, and data-driven enforcement to identify and prevent customs violations, ensure the proper collection of duties, and combat duty evasion and illegal transshipment schemes.

CBP has been transparent about its use of technology and artificial intelligence (AI) to analyze customs entry data, identify risk, and monitor compliance. Importers have experienced this scrutiny through a rise in Requests for Information (CBP Form 28), cargo exams and holds, country-of-origin verification reviews, valuation inquiries, and free trade eligibility validations, among other enforcement activities.

At the recent CBP Trade and Cargo Security Summit (TCSS) in Dallas, TX, CBP discussed a layered approach to implementing enforcement changes outlined in the Executive Order on Strengthening Customs Enforcement issued June 3, 2026. Many of these initiatives are already underway.

One example is CBP's importer identity validation effort. Effective September 19, 2026, importers must maintain an accurate and complete address through the 5106 Importer Identity process or risk the voiding of the importer identification number.

What's on the horizon & key timelines

The Customs Enforcement Executive Order significantly expands importer accountability by increasing Importer of Record (IOR) eligibility requirements, bond coverage expectations, ownership and business disclosure obligations, and compliance oversight.

Within 180 days of the Executive Order, or by November 30, 2026, CBP is directed to begin revising IOR regulations, guidance, and policies including:

• Higher bond and/or domestic asset requirements.
• IOR designation and bonding requirements for both formal and informal entries.
• Additional importer disclosures, including ownership, beneficial ownership information, business affiliations, domestic assets, and anticipated import volumes.

CBP is also directed to strengthen oversight of foreign IORs, increase importer accountability through enhanced data and reporting requirements, and adopt stricter penalty mitigation standards. While CBP has not yet released detailed guidance on many of these initiatives, additional information is expected as the 180-day deadline approaches.

Forced labor enforcement continues to expand

On August 3, 2026, CBP announced the addition of 43 entities to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of listed entities to 187. CBP noted that this represents a 30% increase in listed entities listed and the largest single expansion of the Entity List to date. Agency officials also indicated that additional entities further downstream in supply chains may be added in the future.

Increased supply chain visibility requirements

On September 2,2026, CBP published an Advance Notice of Proposed Rulemaking (ANPRM), Heightened Import Disclosures for Supply Chain Visibility. The proposal would expand importer obligations by requiring greater transparency regarding supply chain participants, enhanced business identifier reporting, and potentially the collection and retention of foreign export documentation to improve traceability and enforcement.

The proposal is designed to help CBP identify illegal transshipment and other customs violations while increasing visibility into imported goods and their supply chains. Comments are due by December 1, 2026, providing importers and supply chain stakeholders with an opportunity to help shape future requirements.

Although there is no prescribed regulatory timeline, the progression from an ANPRM to a Notice of Proposed Rulemaking and ultimately to a final rule can take months or even years. Importers should also be aware that not all enforcement initiatives will require formal rulemaking, and some changes may be implemented more quickly through guidance, policy updates, or operational procedures.

Important steps for importers

Importers can take proactive steps now to prepare for an increasingly complex enforcement environment. The cost of non-compliance continues to rise, making a strong compliance program more important than ever.

Customs compliance

• Ensure imported products are classified correctly under the Harmonized Tariff Schedule.
• Review and update your importer compliance manual and standard operating procedures with your customs broker.
• Establish and actively use an ACE Portal Account to monitor import activity and review ACE reports.
• Conduct periodic audits of customs entries filed on your behalf.
• Subscribe to CBP notices through the Cargo Systems Messaging Service (CSMS) to stay informed of tariff updates, enforcement initiatives, ACE changes, and other trade compliance developments that may impact your imports.
• Participate in the CBP Trade and Cargo Security Summit, either in person or virtually, to stay informed of regulatory changes.

Forced labor/supply chain visibility

• Map your supply chain and understand the origin of raw materials and component parts.
• Regularly review the UFLPA Entity List for updates.
• Utilize CBP forced labor resources, NGO reports, industry publications, and labor rights reports.
• Participate in CBP rulemaking comment periods, including the Supply Chain Visibility ANPRM.

Closing

Customs compliance is becoming increasingly complex as enforcement expectations continue to evolve. Importers that invest in compliance processes, supply chain visibility, and proactive risk management will be better positioned to navigate these regulatory changes, minimize disruptions, and reduce compliance risk.

Now is the time to review your internal controls, compliance procedures, and supply chain documentation to ensure your organization can withstand increased CBP scrutiny. As enforcement efforts become more data-driven and importer accountability requirements continue to expand, importers should evaluate whether they have the processes, records, and visibility needed to support their customs declarations and compliance obligations.

Stay informed

Developments in customs and trade continue to evolve-stay informed to be prepared:

• View our Trade & Tariff Insights
• Subscribe to our Client Advisories