A thousand year problem
For millennia, trade has carried the same disease: smuggling, fraudulent declarations, dangerous goods hiding among honest ones. Ancient tax collectors took bribes. The customs houses of the Silk Road won the right to search but never had the manpower to use it. By the late twentieth century, customs agencies were targeting narcotics and agricultural threats with scanners and task forces, and illicit goods still hid in plain sight, buried in millions of parcels a day.
Customs agencies around the world were forced to manage this massive volume as best they could, so they adopted de minimis. In 2016 the United States raised its threshold to $800, ecommerce exploded, and the risk buried itself in a torrential stream of small parcels. Not because customs stopped caring, but because nothing could keep up with the volume.
Historical fixes to this problem were aimed at the border: more rules, more inspectors, more machines. Customs could only work with what arrived. Catching fraud at the border was one half. Restricting who could import, or what was exported at origin, was too arduous to be practical. The missing ingredient was never at the border.
The missing ingredient was a real entity, in the country of import, within reach of the law, whose name was on the goods, and no way to import without one. That ingredient now exists.
For the honest, this is the best news in a thousand years. For everyone else, it is a countdown.
What just changed
In June 2026 the United States signed an executive order titled Strengthening Customs Enforcement. It is about two things. One: making the importer of record real: a genuine entity with real owners and real assets in the country, not a shell company. Two: being able to hold that person or company accountable for what is imported.
The order reaches imports of every kind, from containers to parcels. This document is about the lane where it changes the most: the low-value ecommerce parcel, the millions of small boxes a day that de minimis taught the world to ship unseen. The pattern is already visible. First a country ends de minimis. Then it strengthens enforcement. The United States has done both. Europe is on the same path, and every major importing nation is somewhere on it.
Every ecommerce import has two records: the real sale, meaning the order, the receipt, the price someone actually paid, and the entry declared to customs. These records drift apart through fraud, negligence, and broken systems. That drift is where every crime in this lane lives.
The executive order closes the drift with a chain of accountability: the logistics provider, the broker, and the importer of record. If you carry small parcels, clear them, or put your name on them, you now own the compliance of everyone downstream of you.
Read what it punishes, then read it backwards, because the punishments are the bar.
- It punishes misrepresentation, and undervaluation above all. So you must know what the goods actually sold for, and whether that price can stand as the entered value.
- It punishes shell companies and sham transactions. It defines a U.S. importer by who actually owns it: controlling beneficial owners who are citizens or permanent residents, or real property in the country. So the humans behind the name on the entry must be real, findable, and actually accountable.
- It punishes withholding information about the goods. So you must know what is actually in the box.
- It requires importers to produce the export documentation the seller filed. That cannot be done for an anonymous seller. This provision alone makes seller identity mandatory without ever saying the word vetting.
- It builds a registry of importers of record in good standing, with recurring vetting that extends to brokers, freight forwarders, and custodians. So the bar is continuous. You never finish meeting it, and your standing reflects the quality of your supply chain.
- It sets penalty floors, strips mitigation from repeat offenders, and expedites seizure. So the era of the five-figure penalty negotiated down to a slap on the wrist is over.
Under de minimis, reasonable care was easy to claim because nobody real had to own the entry. There was no forcing function. Now there is. On low-value ecommerce imports, someone real must own every entry, and that name stays on the entry, auditable, for years after the parcel is forgotten.
The importer of record is the forcing function.
The new bar
You must prove you know the shipper and the seller, prove what was shipped, and validate what it was sold for. Otherwise, how can you claim reasonable care?
Start with what an importer of record actually is, because a decade of de minimis let this lane forget. The United States calls the role the importer of record. Europe calls it the declarant. Every trading nation has a name for it, and every name means the same thing. When you put your name on an entry, you are telling customs: treat these goods as mine. That is the entire legal meaning of the role. You cannot claim ownership of a transaction you know nothing about.
That is why this bar does not really come from the executive order. It comes from what the role has always meant. The order just ends the era of pretending otherwise.
For low-value ecommerce imports, a new bar for the importer of record has been established, and the bar is higher than you think.
First, know the seller. This is the vetting tier: know-your-business, done once at onboarding and refreshed for as long as the seller ships. You should be able to answer as much of this as you can, with proof: What type of product does this company sell? What did they sell recently, and for how much? Are they a new business or an established one? What is their business registration number in their country? Who owns the company, by name? Are they an authorized economic operator (AEO) in their home country? Customs does not hand you this list. The exposure does. Every question you cannot answer is a penalty you cannot defend.
Second, know the shipment. Every entry, every time. This is not a form and it is not a checklist. It is a system.
The second tier requires connecting the platforms where sales actually happen. Matching entries to sale records. Screening codes and origins at machine speed. This is not a paperwork or logistics problem. It is a technology problem.
The knowledge only means something if you hold two capabilities: reach and refusal.
Reach. You can obtain the seller’s own export paperwork, on demand, because you know exactly who they are and they answer when you contact them.
Refusal. You can interrupt a seller’s shipments, today. The next parcel does not leave the country of export, and if it moves anyway, customs already knows to hold it, because you told them. Knowledge without a kill switch is not compliance.
Reasonable care is a standard of process, not outcomes: build the system, run it on every shipment, document what it finds, and act on what it finds.
Where the seller’s sales channel can be connected directly, connect it. Data from the platform where the sale actually happened is the best evidence that exists: the listing, the order, the price, straight from the source.
There is no excuse for skipping independent valuation. Nearly all of this volume is cross-border ecommerce, and for cross-border ecommerce the price actually paid or payable is independently verifiable: a responsible broker can read it straight from the platform where the sale happened. The classic complications of customs valuation (assists, royalties, apportionment, exclusions) are vanishingly rare on a forty-dollar consumer order. So the transaction value is knowable, and any figure the exporter or importer declares that doesn’t line up with the verified price actually paid or payable should raise every flag you have.
A working email address and a working phone number for the exporter, verified, answered. Ecommerce import records are stuffed with dead emails and phone numbers that ring to nobody. If you cannot contact the seller, you do not know the seller.
When nothing validates, refuse the shipment. A refused parcel is the system working.
Every red flag the system raises must end in a recorded outcome: cleared with a reason, evidence reviewed, reported to customs, or the seller shut off. A flag that ends in nothing is the one thing the system must never allow. You cannot always stop an export, but a flag raised in good faith raises your standard of care; see it, stay silent, and clear it anyway, and you own it.
Banking was dragged through this exact moment decades ago, and today no bank on earth considers knowing its customers optional, or even remarkable. It is the cost of touching money, and knowing the seller is about to be the cost of touching imports.
As the importer of record, your reputation and your business are on the line.
The last loophole
Consumer to consumer creates its own challenge, and the bar does not disappear there. It changes shape, and it has three owners.
First, verified identity of the shipper: a real person, reachable.
Second, a vetting process owned by you, the importer of record, alongside the vetting done at the retail counter. Guide the shipper through their declaration so they know what they are attesting to. Get photos of the goods, and watch for the behaviors that mark a bad actor. Take a final attestation, on the record, of what is in the box and what it is worth. An individual who “gifts” forty parcels a week to strangers is not a person; they are an unregistered business, and the pattern will say so.
Third, a final check owned by the logistics provider in the country of export: eyes on the box, or in it, before it ever leaves the country.
A grandmother mailing a sweater passes this bar in about a minute. The “personal effects” trade in commercial goods does not pass it at all.
The broker’s duty
File only for someone who has passed the bar.
If you are both broker and importer of record, you do the full vetting yourself. The seller, the sale, the goods, the pattern. All of it is yours.
If you are the broker and your importer of record does the vetting, you verify that they did. Know your customer’s customer. If your client cannot prove they know their sellers and you file the entry anyway, their failure is now on your license. You are expected to know better.
That is why brokers are named in the penalty provisions, and why repeat offenders lose mitigation. Are you willing to put your license on the line for a client you never verified?
The chain does not stop at the broker. Logistics providers and postal operators choose brokers, and there will be a temptation to choose the cheapest one, the one that asks the fewest questions. When that broker loses its license mid-stream, the parcels that stop moving are yours.
If you don’t want to know the seller, don’t put your name on the entry.
Why global trade just changed forever
I said this is the best news in a thousand years. Here is why. The vast majority of shipments in the world are compliant, or become compliant the moment the right technology touches them at origin and at destination. Sellers with real records have nothing to hide and everything to gain, because for the first time in the history of trade, proof is possible.
When that proof exists, customs can finally trust, with evidence. Green lanes for the proven. Scrutiny concentrated on the unproven. Targeting becomes easier, hiding becomes harder, penalties become real, and the ones held accountable are real people and real companies in the country of import.
Dangerous and illicit goods declining. Revenue collected. Proven sellers moving faster than they ever have. That is the end of a thousand year problem. It just doesn’t look like more inspectors at the border. It is as simple as an accountable name on every entry.
The bar is reachable
I am not writing this from the sidelines. In the year since de minimis ended, Zonos has moved the vast majority of the postal volume entering the United States, and those entries carry our name, filed under our own licensed brokerage. When I talk about the importer of record, I am talking about myself. We see both sides of the transaction: what was sold at origin, and what was declared at import.
We did not wait to be forced. This bar is not one you finish; it is one you hold, shipment after shipment, and we hold it as a system. That system runs on everything that moves under our name, alongside the sellers, marketplaces, logistics providers, and postal operators who move volume with us.
A reckoning is coming. A thousand years of history only bends when someone real is holding the bag, and now someone is.
The bar is higher than you think.