Customs Controls Tighten on Three Fronts: US IOR Numbers Voided Immediately, Mexico Requires Advance Customs Valuation, and EU Platforms Become Importers

As China's National Day Golden Week holiday ends and businesses resume concentrated shipments, customs controls are tightening simultaneously across three major markets: the United States, Mexico and the European Union.

Unlike freight rate fluctuations, customs clearance compliance issues can quickly lead to cargo being held at ports, forced re-exports or even customer claims.

United States: CBP Has Activated Immediate IOR Number Deactivation

On August 19, 2026, US Customs and Border Protection (CBP) published a notice in the Federal Register announcing enhanced importer identity verification measures under Executive Order 14411, “Strengthening Customs Enforcement.” Signed by President Donald Trump on June 3, 2026, the order requires registered importers of record (IORs) to be correctly identified and held accountable for duties owed.

According to the notice, since September 18, 2026, CBP has begun immediately deactivating IOR numbers associated with inaccurate information on CBP Form 5106. A deactivated IOR number is “invalid for any purpose,” including import entry filing.

Key verification requirements include the importer's legal business name, actual operating address (PO boxes, customs brokers' addresses and registered agents' addresses are not accepted), telephone number and email address. All information must be accurate and genuinely belong to the importer.

Customs brokers that knowingly submit false information on behalf of importers may also face penalties.

In March 2026, CBP had already conducted a large-scale IOR cleanup. At that time, 3,826 Chinese containers were reportedly flagged for 5H examinations, of which 3,137 were forced to be re-exported, representing an 82% re-export rate.

The distinguishing feature of this second round of enforcement is “deactivate first, notify later.” Once CBP determines that the information is inaccurate, it will deactivate the IOR number immediately and subsequently notify the importer and the customs broker that filed the most recent entry by email.

For shipments involving third-party importers, Delivered Duty Paid (DDP) arrangements or cross-border e-commerce logistics, businesses should verify the following before dispatch:

• Whether the IOR number is still valid.
• Whether the information on CBP Form 5106 matches the actual importing entity.
• Whether the power of attorney (POA) authorizing the customs broker remains valid.

Mexico: Electronic Customs Valuation Enters the Mandatory Enforcement Stage

On June 2, 2026, Mexico's Tax Administration Service (SAT) and National Customs Agency of Mexico (ANAM) jointly issued an announcement clarifying the mandatory implementation arrangements for the Electronic Manifestation of Value (Manifestación de Valor Electrónica, MVE).

Importers must submit the MVE electronically through Mexico's Foreign Trade Single Window (VUCEM) before customs clearance. The declaration covers the declared customs value, trade terms, payment conditions, contracts and proof of payment.

Electronic MVE submission has been available on an optional basis since August 1, 2025. After several extensions, the mandatory implementation deadline was set under the second version of the proposed rule amendments published on June 2, 2026, extending the deadline to July 31, 2026.

Subsequently, non-compliant or inaccurate declarations may be subject to fines of up to MXN 106,970 per transaction.

Market intelligence published by the US International Trade Administration (ITA) on August 26, 2026, identified inconsistencies among commercial invoices, sales contracts, payment records and trade terms as major triggers for cargo detention and customs audits.

The warning specifically highlighted the electronics, machinery, automotive parts, chemicals and industrial equipment sectors.

For freight forwarders handling China–Mexico shipments, it is advisable to confirm with the Mexican importer that the MVE has been submitted before dispatch. The declared value, product description and transaction terms on the commercial invoice should fully match the information reported in the MVE.

European Union: Customs Reform Becomes Law, Reshaping Platform Responsibilities

On September 19, 2026, the Official Journal of the European Union published Regulation (EU) 2026/2108, formally establishing the revised Union Customs Code and creating the EU Customs Authority.

The regulation entered into force on September 20, 2026, and will become applicable from September 21, 2027. Regulation (EU) No 952/2013 will be repealed when the new rules become applicable.

One of the central changes concerns the allocation of import responsibilities.

Under the new rules, non-EU platforms or sellers selling goods to EU consumers are designated as importers and must take responsibility for customs declarations, payment of duties and taxes, and ensuring that goods comply with applicable requirements.

Platforms or sellers must establish an entity within the EU or appoint an indirect customs representative established in the EU that holds “Trust and Check” status to fulfil these obligations on their behalf.

According to a European Commission press release dated March 26, 2026, approximately 5.9 billion low-value items entered the EU through direct-to-consumer parcel shipments in 2025, with more than 90% originating in China.

The EU abolished the customs duty exemption for parcels valued below €150 on July 1, 2026, replacing it with a temporary €3 customs duty per item tariff subheading. A unified handling fee is scheduled to be introduced no later than November 1, 2026.

In addition, from November 1, 2026, goods sold remotely into the EU must be accompanied by a Product Identifier (PID). The merchant PID will be mandatory. Missing PID data may cause a declaration to be treated as incomplete.

It should be noted that the EU customs reform includes transitional arrangements. Mandatory use of the EU Customs Data Hub is scheduled for March 2034. Until then, member states' existing customs systems will continue to operate in parallel.

Industry Outlook

The tightening of customs controls across these three markets reflects a common trend: the verifiability of the importing entity is becoming a central enforcement priority, overtaking formal compliance with declaration procedures alone.

The United States is directly deactivating invalid IOR registrations; Mexico requires customs valuation information to be electronically verified before clearance; and the EU is legally assigning importer responsibilities to platforms and sellers. These measures reflect the same underlying principle implemented under different jurisdictions.

For freight forwarders, the scope for operating under DDP and “all-in customs clearance and duties-paid” arrangements is becoming increasingly constrained in these markets.

Companies should clearly define customs clearance responsibilities and document-provision obligations in customer contracts to avoid being placed in a difficult position because of deficiencies in importer information.

For US-bound shipments, priority should be given to verifying IOR number status and the validity of information on Form 5106. For Mexico-bound shipments, preparation of MVE documentation should become part of the pre-shipment process. Cross-border e-commerce customers shipping to the EU should assess in advance how the platform's importer status may affect existing logistics arrangements.