Executive Order 14411, signed on June 3, 2026, is often described as a tariff measure. For U.S. importers, the bigger change is who CBP will accept as an importer of record (IOR), and on what terms.

What changes

  • Foreign IORs lose informal entry. Low-value shipments, generally those under $2,500, can no longer be entered informally when the IOR is foreign.
  • Bonds and CTPAT for foreign IORs. On formal entries, a foreign IOR generally may not rely on a continuous bond, and must be CTPAT-validated or file through a CTPAT-validated licensed broker.
  • More disclosure from every IOR. Ownership and beneficial ownership, business affiliations, anticipated import volumes and U.S. assets. Minimum bond coverage goes up, and CBP may require tangible U.S. assets.
  • “Good standing”. Every IOR must stay in good standing with CBP. Compliance history and unpaid duties count.

The order gives DHS 180 days, to about the end of November 2026, for the IOR eligibility, good standing, registry and vetting changes. Final rules and dates are whatever CBP publishes.

A “U.S. IOR” under the order is one organized and located in the United States, with real operations and tangible assets here, and controlled by U.S. citizens or permanent residents, or one that owns significant U.S. real property. A U.S. subsidiary controlled from overseas may well count as a foreign IOR.

Why this favors buying FOB

Many overseas suppliers have shipped to U.S. customers on DDP terms, with a freight forwarder or the supplier itself acting as IOR. As the order makes foreign IORs harder to maintain, expect some suppliers to push for FOB terms, or to stop offering DDP altogether.

If you already buy FOB and clear your own goods, you control the things CBP now cares about: the classification on the entry, the bond, and the records. You also hold the right to any duty refunds, because CBP pays refunds to the IOR on the entry, regardless of what the purchase contract says about who bore the duty.

Four things to check

  1. Your Form 5106 record. Make sure the address on file is a real place of business, not a registered agent, P.O. box or forwarder address.
  2. HTS classification on your top products. Verify each 10-digit HTSUS number at hts.usitc.gov, including Chapter 99 additional duties. A supplier’s Chinese HS code is not a U.S. classification.
  3. Product compliance files. For FCC Part 15 products using a Supplier’s Declaration of Conformity, the U.S. responsible party is typically the importer. Keep test reports and the compliance file on hand.
  4. Supplier terms. If a supplier still quotes DDP, ask who the IOR will be, and what happens to duties, refunds and classification errors.

Where AmCan fits

AmCan’s team in Irvine, California works with overseas manufacturers who want to sell to U.S. importers on FOB terms. If you are reviewing suppliers in light of the new rules, tell us what you are sourcing.

This article summarizes public information and is not legal, tax or classification advice. Check CBP and USITC for current rules, and consult a licensed customs broker.

Mack Ma
Mack Ma

Head of U.S. Market Development at AmCan, Irvine, California.

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