Dear valued client,

We would like to inform you of a recent Executive Order directing U.S. Customs and Border Protection (CBP) and other federal agencies to strengthen customs enforcement efforts.

While the Executive Order does not introduce new tariffs or compliance requirements, it signals increased scrutiny of import compliance, customs documentation, and importer accountability.

Canadian companies acting as Non-Resident Importers (NRIs) into the United States may experience greater oversight from CBP in the coming months.

Businesses operating as the U.S. importer of record, particularly those shipping under Delivered Duty Paid (DDP) terms, should be prepared for increased attention to:

• Tariff classification methodologies
• Customs valuation practices
• Country of origin determinations
• Duty payments and reporting accuracy
• Importer-of-record structures
• Supporting documentation and recordkeeping procedures

CBP is also expected to increase enforcement efforts related to customs fraud, duty evasion, transshipment practices, and compliance with trade measures, including Section 232 requirements.

As a result, importers may encounter additional requests for documentation, compliance reviews, audits, and other enforcement activities.

Although the Executive Order does not change existing customs regulations, it reflects a broader U.S. initiative to strengthen trade enforcement and importer accountability.

Companies should take this opportunity to review their customs compliance programs and ensure that documentation supporting tariff classifications, valuation methodologies, country of origin determinations, and duty mitigation strategies is accurate and readily available.

We will continue to monitor developments and provide updates as additional guidance becomes available.

If you have questions regarding your customs compliance procedures or importer-of-record structure, please contact our team or your usual JORI representative.