NEW EXECUTIVE ORDER MAY REQUIRE CTPAT FOR FOREIGN IMPORTERS AND CUSTOMS BROKERS

Is Your Company Prepared for the New “Strengthening Customs Enforcement” Executive Order?

On June 3, 2026, President Trump signed the Executive Order titled “Strengthening Customs Enforcement,” directing U.S. Customs and Border Protection (CBP) and the Department of Homeland Security (DHS) to implement sweeping new customs enforcement measures focused on foreign Importers of Record (IORs), customs compliance, supply chain transparency, and revenue protection. One of the most significant provisions of the Executive Order may require foreign Importers of Record to either:

• Become validated participants in the Customs Trade Partnership Against Terrorism (CTPAT) program (if eligible); or
• Utilize a CTPAT-validated and licensed customs broker to file entries with CBP.

The Executive Order also directs DHS and CBP to establish additional controls and compliance requirements for foreign importers operating in the United States.

Why This Matters

For years, CBP has expressed concerns regarding foreign Importers of Record that may be difficult to audit, investigate, or hold financially accountable when customs violations occur. The Executive Order seeks to strengthen oversight of foreign importers by increasing accountability, improving customs compliance, and reducing trade fraud. Companies that may be affected include:

• Foreign manufacturers importing directly into the United States
• Non-resident importers
• Foreign-owned U.S. subsidiaries
• Customs brokers
• International freight forwarders
• NVOCCs
• Third-party logistics providers (3PLs)
• E-commerce importers

Industry experts believe this may represent one of the most significant changes to importer accountability and CTPAT participation requirements in the history of the program.

Potential Ramifications for Customs Brokers

Although CBP has not yet released final implementation guidance, the Executive Order specifically references the use of a “CTPAT-validated and licensed customs broker” for qualifying foreign importers. This language may create substantial demand for customs brokers that maintain active CTPAT certification and validation status. Potential impacts may include:

• Increased demand for CTPAT-certified customs brokers
• Competitive advantages for validated brokers
• Increased scrutiny of foreign importer accounts
• Additional documentation and due diligence requirements
• Expanded customs compliance responsibilities

Potential Ramifications for Foreign Importers

Foreign Importers of Record may soon face additional requirements regarding:

• CTPAT participation
• Customs bond eligibility
• Entry filing procedures
• Supply chain transparency
• Import compliance documentation
• Trade enforcement reviews

Importers that currently rely on non-CTPAT customs brokers should begin evaluating their options now to avoid potential disruptions once CBP publishes implementation guidance.

What Is CTPAT?

The Customs Trade Partnership Against Terrorism (CTPAT) is CBP’s premier voluntary supply chain security program. Participating companies work with CBP to implement and maintain security controls designed to protect international supply chains from terrorism, smuggling, forced labor, cargo theft, and other security threats. Benefits of CTPAT participation may include:

• Reduced cargo examinations
• Front-of-line inspection privileges
• Access to Free and Secure Trade (FAST) benefits
• Reduced supply chain disruptions
• Dedicated CBP support through assigned Supply Chain Security Specialists
• Enhanced reputation with customers and business partners

How WE Can Help YOU

CTPAT Security Services, Inc. has assisted hundreds of companies with:

• CTPAT Certification
• CTPAT Validation Preparation
• Annual Security Profile Reviews
• Supply Chain Risk Assessments
• Security Procedures and SOP Development
• Employee Training
• Business Partner Screening
• Internal Audits
• Foreign Manufacturer Compliance Programs

Whether you are a customs broker, importer, exporter, freight forwarder, NVOCC, or foreign manufacturer, our team can help your company understand how the new Executive Order may affect your operations and develop a practical compliance strategy.

CONTACT US TODAY

The implementation details of this Executive Order are still developing, but companies that prepare early will be in the strongest position when CBP begins enforcing new requirements.  PLEASE CONTACT US TO DISCUSS YOUR SITUATION NICK PLATTS: (714) 673-4637 NICK@CTPATSECURITY.COM JEFF PLATTS: (714) 788-1531 JEFF@CTPATSECURITY.COM

Website: www.ctpatsecurity.com