On June 3, 2026, President Trump signed an executive order called "Strengthening Customs Enforcement." Buried in it is the line that should make every procurement and trade-compliance person sit up: a 50% minimum penalty floor on customs violations, plus a directive for maximum penalties against customs brokers who skip due diligence. For procurement teams at companies that import parts, this isn't a tariff story. It's a customs enforcement story, and the bill for a sloppy HTS code or a vague country-of-origin declaration just went up in a way that won't bend.
Most of the coverage framed it as more tariff pressure. That's the wrong read. Tariffs change the price of importing. Enforcement changes the price of getting the paperwork wrong. Those are different problems, and your team probably owns more of the second one than it realizes.
What Actually Changed on June 3?
The order directs CBP and DHS to close the gaps importers have quietly been living in for years: undervaluation, misclassification (wrong Harmonized Tariff Schedule codes), thin importer transparency, and other forms of non-compliance. The headline mechanism is the penalty floor. Before, a customs penalty was negotiable, and a first offense with no intent to defraud often got settled for a fraction of the loss of revenue. A 50% minimum floor takes the soft landing away.
The broker piece matters just as much. The order demands maximum penalties for brokers who fail their due-diligence obligations. Brokers know what that means: they're going to push the liability and the questions back onto you, the importer. Expect more "please confirm the classification" emails, more requests for manufacturer affidavits, more brokers declining to file on a code they can't defend.
Something else happened the same week that shapes the backdrop. A trade court had struck down the 10% Section 122 tariffs in May, but on June 11 the Federal Circuit stayed that ruling, so the duties stay in effect while the appeal plays out. Nobody should plan around them disappearing. Higher duties plus harder enforcement is the combination that actually hurts. When the duty was 2%, a misclassification was a rounding error. When the duty is 25% and the penalty floor is 50% of the underpaid amount, the same clerical mistake is a real number.
Who Carries the Liability When a Broker Files?
This is the part people get wrong. Your broker files the entry, so it feels like their problem. It isn't. The importer of record is legally responsible for the accuracy of the entry, and at a company that buys direct materials, the importer of record is usually the manufacturer. You.
The broker is your agent. They file what you tell them, based on the data you give them: the commercial invoice, the part description, the value, the claimed origin. If your supplier's invoice says "aluminum bracket" and the real HTS classification hinges on whether it's cast or machined, the broker isn't going to walk your shop floor to find out. They'll file something reasonable and move on. Under the old regime, a wrong guess got corrected with a mild penalty. Under the new one, the same guess can carry a 50% floor, and the broker who used to absorb some of that risk now has every incentive to document that you told them what to file.
So the question to ask this week isn't "is my broker doing this right." It's "what data am I handing my broker, and would it survive a CBP audit." That's a procurement question, because procurement owns the supplier data the whole declaration is built on.
What Should Procurement Check This Week?
Don't wait for a recurring task. Pull these five threads now, before the next entry clears.
HTS classification on your high-volume parts. Take your top 20 or 30 imported parts by annual spend and look at the actual codes being declared. Not the codes someone set up in 2021, the ones on the entries clearing today. Misclassification is the most common finding in a customs audit, and it compounds: a wrong code on a part you import 400 times a year is the same error multiplied 400 times. If a code was chosen because it carried a lower duty, that's exactly what the order is built to catch.
Country-of-origin documentation. Origin is where most teams are quietly exposed. The "country of origin" in your ERP is often the supplier's shipping address, which is not the same thing. A part finished in Vietnam from Chinese subassemblies may still be Chinese-origin for tariff purposes, and "substantial transformation" is a legal test, not a vibe. Do you have a manufacturer affidavit on file for your origin claims, or are you taking the supplier's word from an email? If it's the email, that's the gap.
Broker communication. Call your broker and ask, directly, what they're doing differently after June 3. A good one will tell you they're tightening documentation requirements. Ask which of your parts they're least comfortable defending. They know. They've been quietly uneasy about a few of your codes for years.
First-sale valuation support. If you use first-sale to lower your declared customs value (legitimate, common, and now a bigger audit target), make sure the documentation chain actually exists: the factory-to-middleman invoice, proof the goods were destined for export to the US, an arm's-length relationship. First-sale without the paper trail is the kind of thing a 50% floor turns from "give back the savings" into "give back the savings plus half again."
Supplier data hygiene: who's the actual manufacturer? This is the foundational one, and it's the messy reality at most companies. Your vendor master in SAP or NetSuite often lists a trading company or a distributor, not the factory that made the part. For tariffs and origin, CBP cares about the manufacturer, not your purchase order counterparty. If your records can't distinguish the trading company from the producer, you can't accurately declare origin, and you can't fix classification at the source. Most teams discover this gap only when an auditor asks.
Where This Data Actually Lives (and Why That's the Problem)
Here's the uncomfortable truth. The data CBP now expects you to defend is scattered across three places that don't talk to each other.
The vendor master in your ERP holds part numbers and supplier records, but the HTS codes are often stale or copied from a template, and the "manufacturer" field is blank or wrong. The broker's portal (ACE filings, the entry summaries) holds what was actually declared, but procurement rarely logs in there. And the real source of truth (where a part is genuinely made, what it's made of, whether the supplier is the factory or a middleman) lives in supplier emails, attached PDFs, and the heads of two senior buyers.
So when an audit letter shows up asking you to substantiate the origin and classification of a part you've imported 600 times, the answer requires reconciling three systems and interrogating an inbox. That reconciliation is a week of work nobody has, which is exactly why companies settle audits they could have won. The penalty floor punishes the messiness more than it punishes actual fraud, and most of the messiness is data hygiene, not intent.
Most importers are non-compliant right now, not because they're cutting corners, but because their supplier data was never built to answer a customs question. It was built to issue purchase orders and pay invoices. Origin and classification were bolted on. The enforcement order didn't create the exposure. It just attached a price to a gap that was always there.
The Front-Loading Spike Makes This Worse Right Now
There's a timing trap on top of all this. Importers have been front-loading inventory ahead of the new duties and enforcement, and the volume is real. The National Retail Federation's Global Port Tracker forecasts June 2026 US port import volumes at 2.25 million TEU, up 14.3% year over year. Chinese exports to the US surged 35.4% in May 2026 as everyone tried to beat the changes.
What does a front-loading surge look like inside a procurement team? More POs, placed faster, often to beat a deadline. More expedited shipments. More entries clearing in a compressed window. Which means more declarations, more classification decisions, and more origin claims happening exactly when your team is busiest and most likely to take a supplier's invoice at face value. You're increasing the number of customs events at the same moment the cost of getting one wrong jumped. That's a bad combination, and it's happening this quarter.
The follow-up burden compounds it. Every rushed PO is a PO someone has to chase for acknowledgment, ship date, and documents. If your team is already drowning in PO follow-up across hundreds of open orders, the front-loading surge is pouring more water in the boat. The parts that slip through with incomplete origin docs are usually the ones placed in a hurry.
What Are Your Options?
You can't make the enforcement go away. You can shrink your exposure to it.
Run a classification review on your highest-volume, highest-duty parts first. The 80/20 holds: a small set of parts drives most of your customs risk because volume times duty times penalty-floor is where the dollars concentrate. Fixing 20 codes beats fixing 200.
Get manufacturer affidavits on file for your origin claims, especially anything you're claiming as non-Chinese to avoid Section 301. CBP has been aggressive on transshipment for a while, and the new order sharpens it. If you can't prove substantial transformation, you can't defend the claim.
Clean up the manufacturer field in your vendor master so you can tell the factory from the trading company. This is unglamorous and it's the one fix that pays off most, because origin and classification both depend on knowing who actually made the part. It's the same data discipline that makes your approved supplier list worth keeping current instead of being a spreadsheet someone last touched in 2023.
And keep the strategic moves going. The enforcement crackdown doesn't change the underlying case for diversification: the same logic behind building a real tariff procurement strategy and nearshoring your supply base still applies, with the added wrinkle that every new supplier you onboard needs clean origin and classification data from day one. Onboarding a Mexican source to dodge a duty and then mis-documenting its origin just trades one penalty for another.
One more option worth naming, because compliance touches procurement but rarely lives there: figure out who actually owns this. At a lot of companies the answer is "nobody, fully." Trade compliance owns the filing, procurement owns the supplier data, and finance owns the duty spend, and the gap between them is where audits get lost. The penalty floor is a good reason to assign a clear owner before CBP assigns you a bill.
The Price Tag Moved, Not the Rules
The June 3 order didn't change what's compliant. It changed what non-compliance costs. A wrong HTS code or a thin origin declaration used to be a paperwork problem you'd settle quietly. Now it carries a 50% floor, your broker is pushing the liability back to you, and you're processing more entries than usual because of front-loading. The exposure was always in the difference between your direct procurement data and what customs expects. The order just put a price on it.
A lot of customs exposure starts as a data problem: a stale HTS code, a "manufacturer" field that's really a trading company, an origin claim sitting in an email instead of on file. Lumari reads supplier emails and quote PDFs, pulls out who actually made the part and what's in it, and keeps your vendor records current in the ERP, so the data behind your declarations is something you can defend instead of reconstruct.
Sources
The White House, "Strengthening Customs Enforcement" (Presidential Action, June 3, 2026) - https://www.whitehouse.gov/presidential-actions/2026/06/strengthening-customs-enforcement/
U.S. Court of Appeals for the Federal Circuit stays the trade court's ruling against the 10% Section 122 tariffs, June 11, 2026 (the Court of International Trade had struck them down on May 7, 2026) - https://www.skadden.com/insights/publications/2026/05/us-trade-court-strikes-down-section-122-tariffs
National Retail Federation, Global Port Tracker (June 2026 import forecast: 2.25 million TEU, up 14.3% year over year)
CNBC, "China's May shipments to U.S. clock 5-year high growth at 35%" (June 9, 2026) - https://www.cnbc.com/2026/06/09/china-trade-exports-imports-iran-war.html
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