What SCN members need to know about foreign IORs, DDP and U.S. customs brokers
A significant change is coming to U.S. import procedures.
On June 3, 2026, President Trump signed Executive Order 14411 – “Strengthening Customs Enforcement”, directing U.S. Customs and Border Protection (CBP) to tighten requirements for Importers of Record (IORs), including foreign companies importing goods into the United States.
The changes could have a major impact on DDP shipments, foreign IORs and U.S. customs brokers.
🔎 What is changing?
CBP is being directed to increase scrutiny of:
- Ownership and beneficial ownership
- U.S. assets and financial capability
- Customs bonds
- Import history and compliance
- Classification, valuation and country of origin
Foreign IORs will also face greater restrictions on informal entries. For formal entries, foreign IORs that are not CTPAT-validated will generally need to use a CTPAT-validated customs broker.
Importers will also need to maintain “good standing” with CBP.
🤝 What does this mean for forwarders?
Customs brokers will increasingly need to know who their importer really is—who owns it, whether it has the financial capacity to pay duties, whether its business is legitimate and whether its import history is compliant.
This creates additional responsibility for brokers, but also a potential competitive advantage for CTPAT-validated brokers.
🌎 Who could be most affected?
🇪🇺 European exporters using DDP without a substantial U.S. operating entity should review their import structures.
🌏 Asian exporters could see an even greater impact, particularly where DDP is widely used and the overseas seller acts as the U.S. IOR.
🇲🇽 Mexican exporters may be better positioned where established U.S. operations already exist, although foreign-IOR arrangements should still be reviewed.
🚨 What should SCN members do now?
Non-U.S. members: Identify customers importing under DDP or acting as foreign IORs and discuss their arrangements with your U.S. SCN partner.
U.S. members: Review your foreign-IOR customers and ensure you have adequate information on ownership, financial capability, import history and the goods being imported.
💡 Compliance can create opportunity
This isn’t only a compliance issue. Foreign exporters will increasingly need trusted U.S. partners combining customs expertise, IOR knowledge and logistics.
For SCN members, that creates an opportunity to become more than the company moving the freight—it creates an opportunity to become the trusted U.S. trade partner.
The detailed implementing regulations are still to come, but the direction is clear:
Greater scrutiny is coming for U.S. importers and the brokers representing them.
👉 Now is the time to talk to your customers and SCN partners—before the rules force them to change their import model.
For general industry information only; not legal or customs advice.
