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Where the 2026 customs enforcement order stands as of September 14, 2026

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Container truck at a port inspection gate under a gantry crane at dusk, the enforcement environment the 2026 customs executive order addresses

Update, September 16, 2026: one implementation step under the order now has a fixed date. CBP’s August 19, 2026 Federal Register notice begins voiding Importer of Record numbers with inaccurate Form 5106 data on September 18, 2026. The tracker page has a new section on what is in effect and when. The statement below that nothing new is in effect was accurate on September 14 for the order’s rulemaking provisions and remains so for them.

On June 3, 2026, an executive order directed the Department of Homeland Security and U.S. Customs and Border Protection to overhaul customs enforcement. Three months on, the practical position for importers has not changed, and that is the point worth stating plainly.

What is in effect today

Nothing new. The order sets direction. The requirements it describes run through standard rulemaking, and DHS and CBP have been directed to engage stakeholders before anything takes effect. Entry today is still governed by 19 U.S.C. §1484 and 19 C.F.R. Part 141 as they stand, and bonds by 19 C.F.R. Part 113.

What the order points toward

  • Minimum tangible domestic assets, bonding, or both, for Importers of Record
  • Heightened formal entry requirements for foreign entities
  • Informal entry limited to United States Importers of Record
  • A good standing requirement with increased vetting
  • Disclosure and certification requirements
  • A 50 percent minimum penalty floor

The full breakdown, with a visible last-updated date, lives on the 2026 customs enforcement order page. That page is the tracker. It will be revised as notices publish, and each material revision will get a short post here.

Who should be reading the tracker

Companies whose overseas supplier acts as Importer of Record, foreign manufacturers selling into the United States without a US entity, and sellers moving volume under informal entry are the groups most directly in the path of the order. The breakdown by situation describes each one.

Sources

This post summarizes publicly available federal actions for general information. It is not legal advice. Requirements are subject to rulemaking and change. Verify current requirements against the Federal Register and CBP guidance.

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