What does the executive order require?
Trade compliance reporting from BDO and international trade legal coverage describes the order as targeting three primary areas: preventing importation of unlawful goods, tightening eligibility and identification requirements for importers of record, and ensuring compliance with federal laws on timely duty collection. The rollout follows a staggered 90-to-180-day implementation timeline.
| Requirement Area | Timeline | Description |
|---|---|---|
| Importer of record eligibility | 90-180 days | Tightened ID and qualification requirements |
| Supply chain certification | 90-180 days | Certification of compliance with Countering America's Adversaries Through Sanctions Act |
| Supply chain documentation | 90-180 days | Detailed production method and supply chain origin data for imported goods |
| Duty collection enforcement | Immediate priority | Faster enforcement of timely duty payment obligations |
- The 90-to-180-day staggered timeline means some requirements take effect as early as September 2026
- Supply chain certification under the Countering America's Adversaries Through Sanctions Act (CAATSA) is a new formal requirement layered on top of existing forced labor and CTPAT requirements
- Trade compliance reporting describes the changes as "fundamentally changing how merchandise enters the United States"
Which importers are most affected?
Trade legal commentary identifies importers sourcing from higher-risk supply chains — particularly those with upstream production in sanctioned-country supply networks — as facing the most significant new documentation burden. However, trade press coverage and BDO compliance analysis describe the importer-of-record tightening as affecting all importers, not only high-risk categories, given the identity and qualification changes.
Are there risks of delays if compliance paperwork is incomplete?
US airforwarder and trade association reporting notes concerns that the CBP reforms, combined with separate discussions about reducing CBP operational staffing at certain ports of entry, could create processing delays if implementation outpaces CBP's capacity to handle increased documentation volumes. Trade compliance counsel is advising clients to begin gap assessments now rather than waiting for the 90-day window to close.
What Shippers Should Do
- Request a compliance gap assessment from your customs broker against the new importer-of-record and supply chain certification requirements before the first 90-day deadline arrives in early September 2026.
- Confirm that your supply chain documentation is current and can support the new production method and origin data requirements — especially for any upstream suppliers in sanctioned-country networks.
- If you use a third-party importer of record, verify that the IOR meets the tightened eligibility requirements under the executive order before it takes effect.
- Build additional entry processing time into your delivery commitments for August and September shipments, given the possibility of CBP processing adjustment during the rollout period.