Trade & Customs Update: What Shippers Should Know
- Jun 22
- 2 min read
Two developments out of Washington are reshaping the compliance and tariff landscape. Here's a quick overview of what's changing and where to focus.
New Customs Compliance Rules
A June 3 executive order introduces significant changes for importers — foreign and domestic — taking effect within 180 days:
• Foreign importers of record must now hold U.S. assets or bonding — shell companies will no longer qualify
• Informal entry (Type 11) is eliminated for foreign IORs, a method widely used for low-value shipments since the de minimis exemption ended
• Penalty minimums jump to 50% — up from the 10–25% historically negotiated — with no mitigation for repeat offenders
• Brokers are required to conduct greater due diligence on their importer clients
Action: Review any foreign IOR arrangements, confirm your carrier's compliance plans before the rules take effect, and make sure ownership disclosures and supply chain documentation are accurate and current.
Tariff Refunds: Progress — and a Legal Snag
CBP is actively processing refunds for IEEPA tariffs struck down by the Supreme Court earlier this year. Nearly $95B in claims have been accepted through the CAPE refund portal, with ~$24B already sent to the Treasury for payment — and CBP expects to surpass $60B by month's end.
• Reconciliation entries (~$28.7B) targeted for CAPE portal access by June 29
• Finally liquidated entries (~$11.4B) expected late July — though a DOJ appeal over who qualifies may affect the timeline
Action: Work with your customs broker to confirm entry status and eligibility, and monitor the CAPE portal as new phases roll out.
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Source: Supply Chain Dive