Many U.S. companies that manufacture in Asia rely on a simple model: the supplier handles everything. Goods arrive at your door under DDP Incoterms (Delivered Duty Paid), customs-cleared and duty-paid, with your supplier managing it all.
That model often works until it doesn’t.
On June 3, 2026, the White House issued an Executive Order, “Strengthening Customs Enforcement,” that directs U.S. Customs and Border Protection to tighten requirements on foreign Importers of Record, including higher bonds, expanded documentation, and stricter vetting.
For foreign suppliers serving as Importers of Record, these changes may introduce new costs, complexity, and compliance risk. Some suppliers may continue operating as they do today. Others may reassess whether continuing in that role makes economic sense or decide the regulatory burden is simply not worth it.
If your supplier steps back from IOR responsibilities, your goods still need to clear customs, but you may no longer have a designated party responsible for doing so.
This is not just a compliance issue. It is a potential supply chain disruption.
Not sure how your current import arrangement is structured? Contact ITI to find out.
Know Your Options Before You Need Them
The Executive Order is not yet fully implemented, and enforcement details are still being defined. But the direction is clear: foreign Importers of Record are likely to face greater scrutiny.
If your current sourcing model depends on a foreign supplier absorbing customs responsibilities, that may become more expensive, complex, and risky.
The time to identify your alternatives is before a disruption occurs, not after your goods are sitting at port.
How a U.S.-Based IOR Model Can Provide More Stability
ITI Manufacturing has more than 50 years of experience helping U.S. companies source and manage manufacturing overseas. For customers sourcing from Asia and other regions, ITI often serves as the U.S.-based Importer of Record under DDP Incoterms — meaning goods arrive at your facility customs-cleared and duty–paid.
With ITI Manufacturing as your IOR, you get:
- A stable, U.S.-based Importer of Record
- DDP commercial terms with no customs surprises at your door
- End-to-end documentation, compliance coordination, and shipment visibility
- A partner focused on supply chain continuity
For companies that want more control over their overseas sourcing, a U.S.-based IOR model is part of a more stable long-term supply chain strategy.
See how the ITI model works. Learn more.
Next Steps
If your supplier is your Importer of Record, it’s worth understanding your options in case that changes.
Contact ITI Manufacturing to discuss your current sourcing structure and whether a U.S.-based Importer of Record model makes sense for your company.
Frequently Asked Questions
What is an Importer of Record?
An Importer of Record (IOR) is the legal party responsible for ensuring imported goods comply with U.S. customs requirements — including product classification, customs documentation, payment of duties and tariffs, and responding to CBP inquiries about valuation, origin, or compliance.
What is DDP Incoterms?
DDP stands for Delivered Duty Paid. DDP Incoterms is a shipping arrangement in which the seller assumes responsibility for getting goods to the buyer, including customs clearance, duties, and taxes. In many DDP arrangements, the seller also serves as the Importer of Record.
What does the new customs enforcement order do?
The “Strengthening Customs Enforcement” order directs CBP to increase requirements on foreign Importers of Record, including higher bonding levels, stricter vetting, expanded documentation requirements, and increased penalties for violations.
Will my foreign supplier stop serving as my Importer of Record?
It depends. Some suppliers may reassess the economics and decide the added compliance burden is not worth continuing. Others may maintain the arrangement. The point is to recognize that this is a potential risk and plan accordingly, rather than be caught off guard if it changes.
What happens if my supplier decides to stop serving as my IOR mid-shipment?
Your goods may face delays while another party assumes responsibility for customs clearance. This is why it is important to identify your options before a disruption occurs.
What if the Executive Order gets delayed, changed, or overturned?
The regulatory environment may continue to evolve. But the underlying supply chain question remains: does your current model provide sufficient visibility and control over import responsibilities? A U.S.-based IOR partner like ITI Manufacturing can provide operational continuity regardless of how enforcement details develop.
