Importers should review Form 5106 information now to avoid the risk of a voided Importer of Record number
U.S. Customs and Border Protection (CBP) has announced enhanced enforcement measures aimed at verifying the accuracy of Importer of Record (IOR) information submitted through CBP Form 5106, Create/Update Importer Identity Form. The measures take effect September 18, 2026, and apply to both new and existing importers. According to CBP, inaccurate or incomplete information may result in the immediate voiding of an IOR number and other enforcement actions.
For importers, the consequences can be significant. A voided IOR number cannot be used to enter merchandise into the United States, potentially disrupting customs clearance, delaying shipments, and impacting supply chain operations.
Why CBP is increasing scrutiny
The enforcement initiative stems from Executive Order 14411, Strengthening Customs Enforcement, which directs the Department of Homeland Security to confirm that active Importers of Record comply with applicable regulations and disclosure requirements. CBP has stated that accurate importer data is essential for customs enforcement, revenue collection, product safety oversight, and compliance with U.S. trade laws.
As part of this effort, CBP is reviewing importer information currently on file and implementing enhanced procedures to verify that Importers of Record can be properly identified and contacted.
What information is being reviewed?
To establish or update an importer identity, importers submit CBP Form 5106. The form captures key information used to identify the importer and establish importer eligibility. CBP has indicated that its review focuses on core identity and contact information, including:
- Importer legal name
- Employer Identification Number (EIN), Social Security Number (SSN), or CBP-assigned number
- Mailing address
- Physical address
- Telephone number
- Email address
CBP specifically emphasized that information submitted on Form 5106 must be accurate, complete, and belong directly to the importer. The agency stated that customs brokers and other third parties may not provide their own contact information in place of the importer’s information. This includes email addresses, telephone numbers, and physical addresses that do not belong to the importer.
For example, the physical address provided on Form 5106 must be the importer’s actual business or individual location and may not be a P.O. box, customs broker, freight forwarder, registered agent, business service center, or another unrelated party’s address.
What happens if CBP identifies inaccurate information?
Beginning September 18, 2026, CBP may immediately void an IOR number if it determines that Form 5106 information is inaccurate or incomplete. Once voided, the IOR number becomes invalid for all purposes, including the entry of merchandise into the United States. CBP may also pursue additional enforcement actions when appropriate.
If an IOR number is voided, CBP will issue written notice to the importer using the email address most recently provided to the agency. The notice will explain the reason for the action and provide information on the process for requesting reestablishment of the IOR number.
While CBP has established a process for requesting reestablishment, importers should recognize that correcting issues after a number has been voided may take time and could affect ongoing import operations.
What importers should do now
Importers should review the information associated with each active IOR number as soon as possible and confirm that all information is accurate, complete, and current.
Particular attention should be paid to:
- Legal entity name
- EIN, SSN, or CBP-assigned number
- Physical business address
- Telephone number
- Email address
Importers who maintain an Automated Commercial Environment (ACE) Portal account should use the portal to review the information associated with their importer record. Any outdated or incorrect information should be updated promptly.
Companies should also ensure that any customs broker acting on their behalf has accurate, up-to-date information and a valid Power of Attorney authorizing submission of information to CBP.
Importers are advised to review their Form 5106 information before the September 18 enforcement date to reduce the risk of disruptions to customs clearance activities.