Recent developments in the United States highlight a broader shift toward importer accountability. Executive Order 14411 directs federal agencies to strengthen customs enforcement through enhanced importer vetting, increased audits, and expanded collection of ownership and supply chain information. Key enforcement priorities include forced labor compliance, customs valuation, country of origin claims, product safety requirements, and duty collection. 

This policy direction is already being reflected in operational enforcement measures. Beginning September 18, 2026, U.S. Customs and Border Protection will implement steps to enforce the Executive Order, underscoring the growing importance of maintaining accurate importer data and governance controls.

Several major enforcement actions in 2026 further demonstrate the financial consequences of inaccurate customs declarations. Recent cases including one involving an aluminum processing company and related entities and allegations related to a group of steel companies and their part-owner highlight the increasing scrutiny being applied to supply chain records, product histories, and tariff treatment decisions.

Key Takeaways

  • Customs enforcement is expanding beyond entry filings. U.S. authorities are increasingly examining importer ownership structures, supply chain records, valuation methodologies, origin claims, forced labor compliance, product safety requirements, and duty payments, not just the customs declaration itself.
  • Importer accountability is increasing. Executive Order 14411 and upcoming CBP enforcement measures signal heightened scrutiny through enhanced importer vetting, audits, and broader data collection.
  • Enforcement actions demonstrate significant financial risk. Recent U.S. investigations and penalties involving customs declarations, tariff treatment, and supply chain documentation show that inaccurate or unsupported customs positions can result in substantial legal and financial consequences.
  • European customs authorities are using more integrated, data-driven enforcement. EU agencies are combining customs data, logistics information, tax records, and supply chain intelligence to identify high-risk transactions, while reforms aim to strengthen centralized risk management and cross-border information sharing.
  • Documentation and governance are becoming critical compliance requirements. New tariff measures, origin verification standards, direct transport requirements, and customs valuation expectations require importers to maintain robust supporting documentation and be able to clearly justify customs decisions during audits or investigations.

European Authorities Continue to Strengthen Cross-Border Enforcement

Across the European Union, customs enforcement remains coordinated among national customs administrations, the European Commission, the European Anti-Fraud Office (OLAF), and the European Public Prosecutor's Office (EPPO). At the same time, the EU's ongoing Customs Reform is moving toward more centralized risk management and data sharing through a future EU Customs Authority and Customs Data Hub.

Enforcement activity continues to increase. According to the independent public prosecution office of the EU, customs and VAT fraud investigations represented a significant share of active cases and estimated financial losses across the European Union at the end of 2025.

Recent cross-border investigations also demonstrate how authorities are evaluating the complete movement of goods rather than relying solely on customs declarations. A major  inquiry examined possible abuse of transit arrangements and customs procedure 42 involving textiles, footwear, e-bikes, and other products showed how authorities increasingly combine customs data, logistics records, and supply chain intelligence to identify high-risk transactions.

Origin claims remain a particular area of focus. A recent German court conviction of an individual in a case involving Chinese hairdressing foil underscores the importance of validating supplier declarations and maintaining reliable origin documentation throughout the supply chain.

New Duties Bring New Documentation Requirements

Every new tariff measure introduces additional compliance considerations. For example, recent amendments to the Union Customs Code Implementing Regulation introduced new documentation requirements related to demonstrating direct transport or non-alteration for certain goods claiming adjusted EU duty treatment. Importers may need to provide additional evidence regarding the movement of goods through intermediate countries before reaching their final destination.

Customs valuation presents similar challenges. A recent judgment concerning the former Community Customs Code, Grupo Massimo Dutti SA v Administración General del Estado, reinforced the importance of understanding the underlying commercial circumstances surrounding a transaction rather than relying solely on invoice data.

How Descartes Can Help

As customs enforcement becomes increasingly intelligence-driven, companies need solutions that combine authoritative trade content, automation, and governance capabilities.

Descartes CustomsInfo™  helps compliance professionals apply current trade content, manage item-level classification decisions, compare ERP, classification and broker-entry data, and maintain supporting documentation and workflow controls. These capabilities can improve consistency across systems and strengthen an importer’s ability to explain and defend its customs positions during audits or investigations.