We’d like to remind all our customers that Customs and Border Protection (CBP) will begin enforcement procedures to verify the accuracy of the information provided by new and existing importers of record on September 18th, 2026. Please see Customer Advisory “CBP Provides Notice on Accuracy of Importer of Record Data Submissions” for further details.
Beginning on September 18th, CBP states that it will immediately void an Importer of Record (IOR) number if it determines that the importer or its customs broker has failed to provide complete and accurate information on Form 5106. Once voided, the IOR number will be invalid for all purposes, including the entry of imported merchandise. CBP may also pursue additional enforcement action, as appropriate. In practical terms, inaccurate or incomplete importer information could prevent entry processing and disrupt an importer’s shipments until the IOR number is reestablished.
The notice places particular emphasis on the accuracy of the following information reported on Form 5106:
- Physical address: The address must reflect the importer’s actual physical location. It may not be the address of a registered agent, unrelated person or entity, P.O. box, or business-service center. A principal’s home address may qualify if it is genuinely the physical address associated with the business.
- Email address: The email address must be valid and belong to the importer, rather than any other third party.
- Telephone number: The telephone number must be valid and associated with the importer, rather than any other third party.
- Importer identification information: The importer’s legal name and applicable identification number (including an EIN, SSN, or CBP-assigned number) must be accurate and correspond to the importer.
In light of these requirements, all importers should review their current CF 5106 information and verify it against their business and identity records. Any outdated or inaccurate information should be corrected promptly.
If CBP voids an importer number, it will provide written notice to the most recent email address on file for the importer. The notice will identify the basis for the action and explain the process for requesting reestablishment of the IOR number, including the submission of information corroborating the importer’s identity. The importer, or a customs broker acting pursuant to a valid power of attorney, may contact CBP at IORProgram@cbp.dhs.gov using the subject line “Enforcing IOR Accuracy.”
Please reach out to your RIM representative if you have any questions or concerns regarding CBP’s planned enforcement action or if you need assistance reviewing and verifying the accuracy of your existing Form 5106.