Expeditors (EXPD) Status update summary

Policy background and executive order overview

• Recent executive order on strengthening customs enforcement marks a major shift, treating importing as a privilege rather than a right, with increased focus on importer eligibility and supply chain traceability.

• Enforcement priorities include forced labor, misclassification, undervaluation, and illegal transshipment, with expanded vetting of all supply chain parties.

• New requirements will demand more detailed company and supply chain information, including ownership, domestic assets, and export documentation.

• CBP is expected to issue regulatory guidance, with implementation likely over the next 12-18 months.

Enforcement trends and operational changes

• Significant increase in formal customs requests (CF-28/29), with more robust and detailed information demands.

• Importer audits are fewer but yield higher penalties, with liquidated damages and penalties rising sharply.

• DOJ and CBP partnership is stronger, with publicized trade fraud cases and use of the False Claims Act.

• No extensions are being granted for CF-28/29 responses; importers must act quickly and have processes in place.

Key compliance and documentation requirements

• Importers must be in good standing, with all customs liabilities paid and compliance issues resolved.

• New focus on collecting export declarations and supporting documents from the country of export, though specifics are pending.

• Supply chain mapping and documentation for classification, origin, and valuation are critical, especially for high-risk products.

• CBP is leveraging AI and third-party data to verify supply chain claims and manufacturing locations.