The September 18 IOR Deadline: One Wrong Address Voids Your Import Privileges

On August 19, CBP published a Federal Register notice that turns a form most importers haven't thought about in years into an existential threat. Starting September 18, 2026, if CBP decides your Form 5106 data is inaccurate or incomplete, your Importer of Record number gets voided on the spot — and a voided IOR number can't clear a single container. You have 14 days to audit six fields.

The phone number CBP has on file for your company probably rings a desk that was cleared out three years ago. The physical address might be your customs broker's office. The email might belong to a freight forwarder who stopped handling your account in 2024.

Until two weeks ago, none of that mattered. CBP Form 5106 — the Create/Update Importer Identity Form — was the paperwork equivalent of a birth certificate: you filled it out once, probably when you made your first entry, and never looked at it again. Brokers routinely submitted it with their own contact information. Nobody got in trouble.

That era ends on September 18, 2026. CBP published a general notice in the Federal Register on August 19 (91 FR 53627) announcing that it will immediately void the IOR number of any importer whose Form 5106 contains inaccurate or incomplete information. And "immediately" means exactly what it sounds like — no warning letter, no cure period, no 30-day grace window. One day your entries process normally; the next day, ACE rejects everything and your cargo sits at the port racking up demurrage.

Why Now: Executive Order 14411 Comes to Life

This isn't a routine paperwork update. It's the first concrete enforcement action under Executive Order 14411, "Strengthening Customs Enforcement," which President Trump signed on June 3, 2026. The EO declared that importing into the United States "has for too long been treated as a right and not a privilege" and directed CBP to overhaul importer accountability on an aggressive timeline.

The Form 5106 crackdown is Step One. Here's the full enforcement calendar under EO 14411:

The September 18 enforcement is a preview of November's far more sweeping changes. If CBP is willing to void IOR numbers over a stale phone number today, imagine what happens when minimum asset requirements and "good standing" criteria take effect in November.

What CBP Is Checking: The Six Fields That Matter

CBP Form 5106 captures your Importer of Record identity. CBP has confirmed it is comprehensively reviewing records already on file — not just new submissions. Every active IOR in the system is in scope.

The six required fields under review:

The form also collects optional information on business structure, beneficial ownership, and company officers. While CBP's notice focuses on the six required fields, don't assume optional fields are ignored — the notice says CBP "may also pursue other enforcement actions as appropriate."

The Three Shortcuts That Are Now Fatal Defects

For decades, the trade community treated Form 5106 as the broker's problem. Brokers filed it, brokers updated it, and brokers often listed their own information in fields that were supposed to belong to the importer. CBP tolerated this. Starting September 18, three long-accepted industry practices become instant grounds for voiding:

1. Broker or Forwarder as Physical Address

If your Form 5106 lists a customs broker's office, a freight forwarder's warehouse, a registered agent's address, a P.O. box, or a business service center as your physical location, that's now a defect. CBP wants the actual address where your business operates — your office, your warehouse, your headquarters. Not your broker's.

This one catches more importers than any other. Small importers who use a broker for everything — including as their U.S. address of record — are especially exposed. If you're a foreign entity importing through a U.S. broker and your only "physical address" is that broker's office, you have a problem that needs solving in the next two weeks.

2. Broker or Forwarder Contact Information

The phone number and email address on Form 5106 must belong to the importer, not the broker or forwarder. This is a fundamental shift. For years, brokers listed their own contact details so CBP communications would come to the person actually handling the entries. That was practical. Now it's a defect.

CBP will send voiding notices to the email address on file. If that email belongs to your broker and not to you, there's a real scenario where your IOR gets voided and you don't even find out until your next shipment fails.

3. Power of Attorney Through a Third Party

Customs brokers must hold a power of attorney (POA) executed directly with the Importer of Record. POAs routed through a freight forwarder or other intermediary no longer satisfy CBP's requirements. If your broker's POA came through your forwarder — a common arrangement in supply chains where the forwarder manages the broker relationship — that chain needs to be corrected.

The Consequences of a Voided IOR Number

A voided IOR number isn't a suspension or a warning. It's a full stop:

• No entries: ACE will reject every entry summary filed under that IOR number. Your cargo doesn't clear.
• No advance warning: CBP's notice doesn't promise a pre-voiding notification. You may learn about it when your next shipment fails.
• Port costs stack immediately: Demurrage, detention, and storage charges begin accumulating the moment cargo can't clear. At major ports, container demurrage alone runs $150-$400 per day after the free time expires.
• Cascading delays: If you're a manufacturer with just-in-time supply chains, a voided IOR doesn't just delay one shipment — it shuts down your inbound pipeline until reestablishment.
• Additional enforcement exposure: The Federal Register notice warns that inaccurate Form 5106 information may also expose importers to consequences under other statutes, including potential civil penalties.

How to Reestablish a Voided IOR Number

CBP has provided a dedicated channel for reestablishment requests:

• Email: [email protected]
• Subject line: "Enforcing IOR Accuracy"
• Contact: Anita Rivera, Branch Chief, Revenue Enforcement Branch, Trade Modernization Division, (771) 233-2939

But here's what CBP hasn't disclosed: how long reestablishment takes. There's no published timeline, no guaranteed SLA, and no expedited process for importers with cargo sitting at the port. Every day waiting for reestablishment is a day your supply chain is frozen.

The smart move is obvious: don't get voided in the first place.

Your 14-Day Audit Checklist

You have until September 18 to get your Form 5106 right. Here's the step-by-step:

1. Pull your current Form 5106 data from ACE — Log into the ACE Secure Data Portal and review your IOR profile. Compare every field against current reality, not what was true when you first registered.

2. Verify your physical address — It must be your actual business location. If it's a broker's office, a P.O. box, a registered agent, or a business service center, update it to your real address immediately.

3. Check the phone number and email — Both must ring and land at your organization, not your broker's or forwarder's. If CBP sends a notice to the email on file, will someone at your company actually see it?

4. Confirm your EIN is current — If your entity has gone through mergers, acquisitions, or restructuring, make sure the EIN on file matches your current IRS records. Dissolved entities with active IOR numbers are an obvious target.

5. Audit your power of attorney — Your customs broker must hold a POA executed directly between your company and the brokerage. If the POA was routed through a freight forwarder or other intermediary, execute a new one directly.

6. File an updated Form 5106 if anything changed — Don't wait. Submit the corrected form through ACE now. A proactive update before September 18 is infinitely easier than a reestablishment request after voiding.

7. Set a recurring review — This isn't a one-time fix. CBP's notice says the agency is "comprehensively reviewing" all IOR records on file. Build Form 5106 accuracy into your quarterly compliance review.

What's Coming Next: November 30 and Beyond

The Form 5106 crackdown is the warm-up act. EO 14411's 180-day mandate hits November 30, 2026, and it's far more sweeping:

• Minimum domestic assets or bonding: Every IOR will need to maintain a minimum level of tangible U.S. assets, bonding, or both — amounts TBD by CBP.
• Increased minimum bond coverage: Current bond amounts will likely go up, potentially significantly.
• New "good standing" requirement: CBP will develop criteria that every IOR must continuously meet. Losing good standing means losing import privileges.
• Enhanced vetting for foreign IORs: Foreign entities will face additional documentation, including submitting any information previously provided to foreign customs authorities.
• Registry cleanup: CBP will purge IOR numbers that don't meet the new eligibility standards.
• Risk tiering: CBP will implement a formal risk-tiering framework, meaning your compliance history will directly affect how your entries are processed.

The importers who treat September 18 as a fire drill and fix their Form 5106 data are the same ones who'll be positioned for November's changes. The ones who scramble to reestablish a voided IOR number in October will be starting from behind.

This Is the New Normal for Importers

Three months ago, CBP started auto-deactivating IOR numbers that hadn't filed an entry in 366 days. Now they're voiding numbers for stale contact information. In November, minimum asset requirements arrive. The pattern is clear: CBP is systematically raising the bar for who gets to import into the United States.

The era of filing Form 5106 once and forgetting it is over. Import privileges now require active maintenance — current data, direct relationships, and continuous compliance. The importers who build those habits now will keep their supply chains moving. The ones who don't will find out the hard way that a voided IOR number is the most expensive paperwork mistake in trade.

TariffLens tracks enforcement deadlines and compliance requirements so you can catch issues like outdated Form 5106 data before CBP does — not after your cargo is stuck at the port.

This article is for informational purposes only and does not constitute legal, tax, or customs advice. Consult a licensed customs broker or trade attorney for guidance specific to your situation.