New U.S. Customs Requirements for Foreign Importers: What Australian Businesses Need to Know

U.S. customs compliance is set to become more demanding for foreign businesses importing goods into the United States.

On 3 June 2026, the U.S. Government issued Executive Order 14411, Strengthening Customs Enforcement, directing the Department of Homeland Security and U.S. Customs and Border Protection (CBP) to introduce a range of measures aimed at strengthening importer accountability, customs compliance and enforcement.

For Australian businesses using a Foreign Importer of Record (FIOR) arrangement, understanding these changes early will be important.

What Is Changing?

Under the Executive Order, foreign Importers of Record making formal entries will face additional requirements. These include measures requiring a foreign IOR to either be eligible for and validated in CBP’s Customs Trade Partnership Against Terrorism (CTPAT) program, or use a CTPAT-validated and licensed customs broker to file entries with CBP.

The order also directs CBP to introduce additional requirements covering importer eligibility, bonding, disclosure, verification and compliance history.

For foreign IORs, the changes include:

• Restrictions on filing informal entries
• Limitations on the use of continuous bonds, subject to exceptions permitted by CBP
• Additional disclosure of ownership, beneficial ownership, business affiliations and U.S. assets
• Enhanced information requirements relating to anticipated import volumes and imported goods
• A new “good standing” framework based on compliance history and payment of customs liabilities
• Enhanced and recurring vetting of parties involved in the import process

The Executive Order also directs CBP to strengthen information and certification requirements relating to imported products and their supply chains.

Why Does This Matter to Foreign Importers?

For Australian businesses importing into the United States, the changes could make the importer onboarding and customs clearance process more detailed and time-sensitive.

Importers should ensure that key information is accurate and readily available, including:

• Importer of Record details
• Ownership and beneficial ownership information
• Powers of Attorney and broker instructions
• Product descriptions and classifications
• Valuation information
• Manufacturer and supply chain details
• Expected import volumes
• Relevant customs and compliance documentation

The Executive Order is designed to increase CBP’s ability to verify importers and enforce U.S. customs requirements. Businesses should therefore expect greater scrutiny and should avoid leaving importer setup or documentation until cargo is already in transit.

When Will the Changes Take Effect?

Implementation will occur progressively rather than on a single effective date.

The Executive Order directs certain actions to be taken within 90 days, including measures relating to additional import documentation and information.

A number of significant IOR-related changes are directed to be implemented within 180 days, including revisions to importer eligibility, “good standing” requirements, IOR registry updates and enhanced vetting procedures.

This means businesses have an opportunity to review their current arrangements and prepare before all of the new requirements are implemented.

However, the precise operational requirements will depend on the regulations, guidance and policies subsequently issued by CBP and other relevant authorities.

What Should Businesses Do Now?

Foreign companies importing into the United States should consider reviewing their existing arrangements now rather than waiting for implementation deadlines.

In particular, businesses should:

Review your FIOR arrangements
Confirm who is acting as the Importer of Record and whether the current arrangement is likely to meet the evolving requirements.

Review your customs documentation
Ensure Powers of Attorney, importer information, product classifications, valuations and broker instructions are complete and accurate.

Review your supply chain information
The new framework places greater emphasis on information about imported goods, manufacturers and supply chains.

Allow additional time
Enhanced verification and onboarding requirements may add time to the customs setup process, particularly where additional information is required.

Work with experienced customs and logistics partners
Early review can help identify potential compliance issues before cargo is exported to the United States.

What This Means for Australian Importers

The changes form part of a broader move toward greater customs enforcement and importer accountability in the United States.

For Australian businesses, the key takeaway is simple: FIOR arrangements should not be treated as an administrative formality.

Importer eligibility, documentation, compliance history and customs processes may all come under greater scrutiny as CBP implements the Executive Order.

Preparing early can help businesses reduce the risk of avoidable delays and ensure their U.S. import arrangements are ready as the new framework takes shape.

McHugh & Eastwood Perspective

At McHugh & Eastwood, we recognise that changes to customs requirements can have implications well beyond the border. They can affect shipment planning, documentation, costs and delivery timelines.

We recommend that businesses with upcoming U.S. imports review their FIOR arrangements and engage their customs broker or trade adviser early.

We will continue to monitor developments and keep our clients informed as further CBP guidance and implementation measures are released.

If you have questions about how these changes may affect your U.S. imports, speak with the McHugh & Eastwood team before your next shipment is exported.