CBP Is Watching: What the June 3 EO Means for Importers

New EO changes the stakes for importers

On June 3, 2026, President Trump signed the Executive Order (EO) titled Strengthening Customs Enforcement, directing U.S. Customs and Border Protection (CBP) and the Department of Homeland Security to implement sweeping reforms aimed at improving customs compliance, increasing accountability for importers, and combating duty evasion and customs fraud. The order places significant emphasis on ensuring that importers of record are properly vetted, adequately bonded, and fully accountable for the accuracy of information reported to CBP.

While much of the attention surrounding the EO has focused on increased bonding requirements, importer vetting, and tougher penalties, importers should pay particular attention to what the administration has identified as key areas of noncompliance: undervaluation of imported merchandise, inaccurate reporting of import data, and schemes designed to avoid the payment of lawful duties. The EO specifically cites undervaluation and incomplete import information as examples of practices that undermine customs enforcement and federal revenue collection.

For importers, this means that proper tariff classification and customs valuation are more important than ever. Every entry filed with CBP relies on accurate Harmonized Tariff Schedule (HTS) classification and declared value. An incorrect classification can result in underpayment or overpayment of duties, while improper valuation can expose a company to penalties, liquidated damages, and increased scrutiny during audits or investigations. With CBP expected to enhance enforcement efforts and establish a minimum penalty floor for customs violations, the financial consequences of errors may become more significant than in the past.

Many importers have experienced substantial changes in duty exposure over the past several years due to Section 301 duties, Section 232 measures, IEEPA tariffs, and other trade actions. As duty rates increase, so does CBP's interest in ensuring that merchandise is properly classified and accurately valued. Even a seemingly minor classification error can have a substantial impact when applied across large import volumes.

As customs professionals, we frequently find that classification decisions made years ago continue to be used without periodic review, despite changes in product design, sourcing, tariff provisions, or CBP guidance. Similarly, valuation practices may evolve over time as companies restructure supply chains, establish related-party transactions, or implement new purchasing arrangements. These changes can create compliance risks that may not be immediately apparent.

The EO serves as a reminder that import compliance should not be viewed as a one-time exercise but as an ongoing process. Importers may benefit from periodically reviewing their classification methodologies, valuation practices, country-of-origin determinations, and supporting documentation to ensure they remain aligned with current regulations and CBP expectations.

With CBP signaling a more aggressive enforcement posture and a renewed focus on duty collection, importers should take this opportunity to evaluate the accuracy of their customs data before regulators do. A proactive review can help identify potential issues, strengthen compliance procedures, and provide confidence that import operations can withstand increased government scrutiny in the years ahead.