Strengthening Customs Enforcement

6/3/2026
Executive Orders

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Action Summary

  • Purpose: Enhance customs enforcement to protect national security, foreign policy, and the economy by preventing the importation of unlawful/dangerous goods and ensuring adherence to federal laws (e.g., forced labor, intellectual property, revenue collection, and product safety).
  • Importers of Record (IOR) Reforms:
    • Revise eligibility regulations within 180 days, requiring IORs to maintain a minimum level of tangible domestic assets or bonding and enhancing bond requirements.
    • Mandate detailed data disclosures from IORs, including anticipated import volumes, ownership details, and domestic asset disclosures.
    • Implement differentiated treatment: foreign IORs face stricter measures (e.g., prohibition on filing informal entries and additional requirements for formal entry) to ensure equal footing and safeguard U.S. revenue and industries.
    • Establish “good standing” criteria for IORs, with non-compliant IORs barred from importing goods.
    • Update the IOR registry and create risk-based tiers based on compliance history and related factors.
    • Introduce enhanced vetting procedures for all entities involved in import activities.
  • Import Disclosure and Certification Requirements:
    • Establish heightened requirements for certification of supply chain compliance with applicable laws.
    • Mandate disclosure of foreign tax and global business identifiers and detailed product information.
    • Require submission of documentation from foreign exporters regarding prior customs administration information within 90 days.
  • Enforcement and Penalties:
    • Bolster enforcement actions by increasing audits, enforcing liquidated damages, restricting in-bond utilization, and imposing maximum penalties on noncompliant brokers.
    • Emphasize prioritization of enforcement against importations linked to forced labor, misclassification, undervaluation, and illegal transshipment.
    • Revise mitigation standards to establish minimum penalty floors and eliminate mitigation for repeat offenders.
  • Streamlined Disposal: Expedite seizure and disposal of non-compliant imports by reducing regulatory burdens, increasing bond requirements for high-risk shipments, and authorizing third-party disposal within 90 days.
  • Transparency Measures:
    • Enhance customs transparency by establishing periodic reviews and expiration of confidentiality requests.
    • Publish annual enforcement transparency reports in consultation with relevant agencies.
  • Legislative and Reporting Requirements:
    • Submit legislative recommendations to strengthen customs enforcement within 45 days.
    • Report to the President and relevant officials on the order’s effectiveness within 1 year.
  • Definitions and Structural Provisions:
    • Clarify definitions for “U.S. IOR” and “foreign IOR,” including criteria for being “located in the United States.”
    • Address additional legal provisions including severability, general implementation procedures, and limitations on creating enforceable rights.

Risks & Considerations

  • The Executive Order on strengthening customs enforcement highlights the necessity for rigorous compliance with U.S. trade laws. This could place increased pressure on Vanderbilt University’s international partnerships and research collaborations, especially if they involve foreign importers or customs procedures.
  • Increased scrutiny on importers of record (IORs) may lead to complications for any university programs that rely on imported goods for research or educational purposes. The requirement for enhanced data disclosures may necessitate additional administrative resources to ensure compliance.
  • The reforms may lead to heightened penalties for noncompliance, which could impact university vendors and partners, potentially raising costs or disrupting supply chains for necessary educational materials.
  • Vanderbilt University must evaluate how these changes could influence its research funding opportunities, especially if federal grants or contracts prioritize institutions with strong compliance records under the new regulations.

Impacted Programs

  • Office of Sponsored Programs: May need to adjust compliance frameworks to align with new customs enforcement regulations, ensuring that all imported materials meet the outlined requirements.
  • International Relations Office: Could face challenges in managing partnerships with foreign institutions. The complexities of customs enforcement may hinder collaborative research projects that rely on international resources.
  • Research Departments: Those involved in projects with imported materials will need to reassess their procurement strategies and compliance measures to avoid potential penalties.

Financial Impact

  • Potential increases in operational costs due to the need for compliance with new customs regulations and possible penalties for noncompliance could strain departmental budgets.
  • Changes in funding opportunities as federal grants may prioritize institutions that demonstrate compliance with customs enforcement, potentially affecting the university’s ability to secure necessary funding.
  • Increased requirements for documentation and compliance may necessitate hiring additional staff or reallocating resources, impacting overall financial health.

Relevance Score: 4

Key Actions

  • The Office of Federal Relations should monitor the implementation of the customs enforcement reforms mandated by the executive order to assess their impact on trade compliance and potential funding for research related to international trade and customs policy. This will be important for aligning Vanderbilt’s initiatives with new federal regulations and ensuring the university’s interests are represented in discussions about enforcement priorities.
  • Vanderbilt’s Law School can engage in research and advocacy to address the legal implications of the new customs enforcement measures, particularly regarding the treatment of foreign importers and the balance between national security and trade facilitation. This can position the law school as a leader in this evolving area of law.
  • The Department of Political Science should analyze the political ramifications of the executive order on international relations and trade policies. Conducting research on how these changes affect U.S. relations with trading partners can provide valuable insights that can inform policy discussions and Vanderbilt’s advocacy efforts.
  • Vanderbilt’s Business School should evaluate the potential economic impacts of the customs reforms on local and national businesses, particularly in sectors heavily reliant on imports. Understanding these dynamics will be crucial for advising stakeholders and aligning curriculum with real-world business challenges.
  • The Office of Sponsored Programs should seek to identify new funding opportunities arising from federal initiatives aimed at enhancing customs enforcement and compliance research. This proactive approach will help secure grants that align with Vanderbilt’s strategic goals in research and innovation.
  • The Center for International Studies should initiate partnerships with other universities and organizations to study the effects of stringent customs regulations on global trade dynamics. This collaborative research can enhance Vanderbilt’s reputation and contribute to the broader understanding of international trade issues.

Opportunities

  • The executive order presents an opportunity for Vanderbilt’s School of Engineering to develop technologies that facilitate compliance with new customs regulations, such as software solutions for tracking imports and ensuring adherence to reporting requirements. This aligns with the university’s focus on innovation and technology transfer.
  • Vanderbilt can leverage its expertise in policy and trade to influence the development of best practices for compliance with new customs enforcement measures. By hosting workshops or conferences, the university can establish itself as a thought leader in this area, attracting attention from policymakers and industry leaders.
  • The Vanderbilt Institute for Global Health can explore the implications of customs enforcement on the importation of medical supplies and pharmaceuticals. Engaging in research that addresses potential barriers to access for critical health supplies can position Vanderbilt as a key player in global health policy discussions.
  • By actively participating in discussions about the implications of customs reforms, Vanderbilt can shape the narrative around trade compliance and national security, ensuring that the university’s perspectives are included in national dialogues.
  • The university can enhance its outreach to international students and businesses affected by the new customs regulations, providing resources and support to navigate these changes. This initiative could improve Vanderbilt’s relationship with the international community and attract diverse talent.

Relevance Score: 4 (The order presents the potential for major process changes required for Vanderbilt’s engagement in trade compliance and policy research.)

Average Relevance Score: 3.8

Timeline for Implementation

  • Within 45 days of the date of this order: Submission of recommendations for legislation on customs enforcement (Section 8).
  • Within 90 days of the date of this order:
    • Establish import disclosure and certification requirements for foreign exporters (Section 3(b)).
    • Revise mitigation standards (Section 4(c)).
    • Streamline disposal of non-compliant imports (Section 5).
    • Enhance transparency measures in customs (Section 6).
  • Within 180 days of the date of this order:
    • Revise importer eligibility regulations and guidance (Section 2(a)).
    • Require all IORs to maintain “good standing” (Section 2(d)).
    • Update the IOR registry (Section 2(e)).
    • Establish enhanced vetting procedures for import-related entities (Section 2(f)).
  • Within 1 year of the date of this order: Submit a report on the effectiveness of these measures (Section 9).

Relevance Score: 4

Impacted Government Organizations

  • Department of Homeland Security (DHS): The order mandates that the Secretary of Homeland Security take numerous enforcement actions, revise policies, and update regulations related to customs enforcement.
  • U.S. Customs and Border Protection (CBP): As an arm of DHS, CBP is tasked with revising importer eligibility, updating the IOR registry, defining “good standing,” and enforcing customs compliance measures.
  • Department of Justice (DOJ): The Attorney General, representing DOJ, is referenced for taking enforcement actions, particularly regarding investigations of fraudulent import practices and illegal transshipments.
  • Office of Management and Budget (OMB): The Director of OMB is involved in consultation for submitting legislative recommendations to strengthen customs enforcement.
  • United States Trade Representative (USTR): USTR is involved in the reporting framework, receiving a report on the order’s effectiveness.
  • Executive Policy Offices (e.g., Senior Counselor for Trade and Manufacturing & Assistant to the President for Economic Policy): These offices are part of the directive’s implementation and legislative recommendation process.

Relevance Score: 2 (Between 3-5 agencies are directly impacted by this executive order.)

Responsible Officials

  • Secretary of Homeland Security – Tasked with revising importer eligibility regulations, updating the IOR registry, establishing enhanced vetting procedures, streamlining customs enforcement operations, enhancing transparency measures, and overall ensuring that U.S. customs and trade laws are effectively enforced.
  • Attorney General – Shares responsibility with the Secretary to enforce customs laws, including taking action on investigations into forced labor and noncompliant practices by brokers.
  • Director of the Office of Management and Budget – Consulted to provide recommendations for related legislative proposals, in conjunction with the heads of other relevant agencies.
  • Heads of Relevant Executive Departments and Agencies – Involved in consultations to establish heightened import disclosure, certification requirements, and transparency measures, and to ensure execution of associated policies across federal agencies.

Relevance Score: 5 (Directives significantly affect cabinet-level officials and top agency heads integral to national security and customs enforcement policy implementation.)

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