CBP Will Void Your Importer Number on September 18: Fix Your Form 5106 Now

Starting September 18, 2026, U.S. Customs and Border Protection will immediately void the Importer of Record number of any company with inaccurate or incomplete information on CBP Form 5106. A voided IOR number means you can't import goods into the United States — full stop. Here's exactly what CBP is checking and what you need to fix in the next 18 days.

Imagine this: your container arrives at the Port of Long Beach on September 19. Your customs broker submits the entry. And instead of a release, CBP sends back a rejection — your IOR number has been voided. No warning letter. No courtesy call. Your cargo sits at the port racking up demurrage charges while you scramble to figure out what happened.

That scenario becomes very real in less than three weeks. On August 19, 2026, CBP published a Federal Register notice announcing that it will begin voiding IOR numbers for inaccurate or incomplete Form 5106 data starting September 18, 2026. This isn't a proposed rule or a request for comment. It's a general notice with a hard enforcement date, and it applies to every active importer in the country.

The kicker? Several practices that brokers and importers have relied on for years — using a broker's address on the 5106, listing a freight forwarder's phone number, or filing with a registered agent's email — are now explicitly flagged as defects that can trigger an immediate void.

Executive Order 14411: The Enforcement Engine

This isn't CBP acting alone. The Form 5106 crackdown is the first concrete implementation step of Executive Order 14411, "Strengthening Customs Enforcement," signed by President Trump on June 3, 2026. Section 2(e) of the EO directs the Department of Homeland Security to confirm that all active Importers of Record comply with applicable regulations and disclosures.

The executive order was itself a response to growing concerns about tariff evasion. A recent White House report estimated that between $40 billion and $150 billion in Chinese-origin goods are being transshipped through third countries to avoid U.S. tariffs. Verifying who's actually importing goods into the country is the logical first step in closing that gap.

CBP has now moved from directive to action. The agency stated in the Federal Register notice that it is "comprehensively reviewing" the Form 5106 information on file for all importers of record — not a sample, not a random audit, but a review of every active IOR in the system.

What CBP Form 5106 Actually Is

For importers who've never had to think much about this form, here's the quick version. CBP Form 5106, the Create/Update Importer Identity Form, is the document that establishes your identity with Customs. When you or your broker submits it, you're registered as an Importer of Record with a unique IOR number tied to your Employer Identification Number (EIN), Social Security Number (SSN), or a CBP-assigned number.

Every formal entry filed with CBP references your IOR number. It's the thread that connects your shipments, your bonds, your duty payments, and your compliance history. If that number gets voided, the thread breaks — and every shipment in your pipeline stops.

The form captures these data elements:

• Importer name (legal entity name)
• IRS Employer Identification Number (EIN) or SSN
• Mailing address and physical address
• Email address
• Phone number
• Contact information for authorized individuals

Until now, the accuracy of this information hasn't been aggressively policed. That changes on September 18.

The Five Data Points CBP Is Verifying

Based on the Federal Register notice and CBP's guidance, here are the specific fields CBP will validate — and what now counts as a defect.

1. Physical Address

The requirement: The address on file must be the actual physical location of the importer's business or the individual's residence.

What's now a defect: Using the address of a registered agent, customs broker, freight forwarder, P.O. box, business service center, virtual office, or any other third party. This is a big one. Many importers — especially foreign-based companies importing into the U.S. — have historically used their broker's or agent's address on the 5106. That practice is now grounds for an immediate void.

2. Email Address

The requirement: The email address must belong directly to the importer or an authorized officer of the importing entity.

What's now a defect: A customs broker's email, a freight forwarder's email, or any third-party email address. The email must be traceable to the IOR itself.

3. Phone Number

The requirement: The phone number must be a working number that reaches the importer directly.

What's now a defect: Listing a broker's phone number, a logistics provider's number, or a disconnected line. CBP wants to be able to reach the actual importer.

4. EIN or SSN

The requirement: The tax identification number must be accurate, valid, and belong to the importing entity.

What's now a defect: Transposed digits, expired EINs, or numbers that don't match IRS records. If you've had a corporate restructuring or name change and didn't update your 5106, you're at risk.

5. Importer Name

The requirement: The legal name on the 5106 must match the entity's actual legal name as registered with the IRS.

What's now a defect: Trade names, DBAs, or outdated corporate names that don't match the EIN on file.

Why "Long-Accepted" Practices Are Now Defects

Here's what makes this enforcement action particularly disruptive: CBP is explicitly targeting practices that have been standard operating procedure in the brokerage industry for decades.

It's been common for customs brokers to file Form 5106 using their own address, email, and phone number as a convenience for clients — especially foreign importers who don't have a U.S. presence. The form got filed, the IOR number got activated, and nobody looked too closely at the contact details.

That era is over. As Diaz Trade Law noted in their analysis, "several long-accepted industry practices are now defects." The shift reflects CBP's broader strategy under EO 14411: if the agency can't verify who an importer actually is and where they're actually located, that importer doesn't get to import.

For customs brokers, this creates an urgent client communication challenge. Every client whose 5106 lists the broker's contact information needs to be identified and updated — and there are only 18 days to do it.

What Happens When Your IOR Number Is Voided

The consequences are immediate and severe:

That last row is particularly important. CBP's notice specifically warns that inaccurate information may expose importers and associated individuals to liability under federal false statement statutes and the False Claims Act. For customs brokers who filed inaccurate 5106s on behalf of clients, the customs broker penalty provisions under 19 USC 1641 are also in play.

The Reactivation Process

If your IOR number does get voided, here's the process CBP has outlined:

1. Email CBP at [email protected] with the subject line "Enforcing IOR Accuracy"
2. Submit a corrected Form 5106 with accurate, complete information
3. Include supporting documentation — valid importer record proof and Power of Attorney (if signed by an Attorney-in-Fact, the POA must be no more than one year old)
4. The 5106 must be signed by an officer of the company (President, VP, Secretary, Treasurer, CEO, COO) or a broker with valid POA
5. Wait for processing — CBP typically takes 5 business days to update an existing IOR

Five business days might not sound like much. But if you have containers arriving daily, five days of voided IOR status means five days of cargo piling up at the port, five days of demurrage charges, and five days of missed delivery commitments to your customers.

Your Pre-September 18 Checklist

You have 18 days. Here's what to do with them.

1. Pull your current Form 5106 from ACE — If you don't have a copy, ask your customs broker. Review every field against the requirements above.

2. Verify your physical address — Is it your actual business location? If it's a broker's address, a registered agent, a P.O. box, or a virtual office, it needs to change. Foreign importers without a U.S. physical location should consult with their broker about compliant alternatives.

3. Check your email and phone — Both must belong to the importing entity, not a third party. Update to a company email and a direct company phone number.

4. Confirm your EIN matches IRS records — If you've had a corporate restructuring, merger, or name change, verify that your EIN and legal name are current with both the IRS and CBP.

5. Submit updates through your broker via ABI — Licensed customs brokers with ABI access can retransmit updated 5106 data to CBP electronically. This is faster than emailing a paper form.

6. Don't wait until September 17 — CBP takes up to 5 business days to process updates. Submit corrections no later than September 10 to have a buffer before the enforcement date.

7. Customs brokers: audit your client files — Identify every client whose 5106 lists your firm's contact information and initiate outreach immediately. Document your efforts — if a client's IOR gets voided and you can show you proactively flagged the issue, that's a meaningful distinction.

What's Coming Next

The Form 5106 enforcement is just the opening move under EO 14411. The executive order's other provisions include:

• Enhanced bonding requirements for importers flagged as high-risk
• Expanded use of EAPA (Enforce and Protect Act) investigations for tariff evasion
• Mandatory disclosure obligations that could require importers to report compliance deficiencies
• Coordination between CBP and DOJ on trade fraud — the new DOJ Trade Fraud Resource Guide, announced in late August 2026, formalizes this partnership

CBP has also signaled that the IOR verification program will become ongoing, not a one-time sweep. Importers should expect periodic re-verification and should build Form 5106 accuracy into their regular compliance reviews.

The Bigger Picture

This enforcement action fits into a clear pattern. Between the EAPA program surpassing $1 billion in uncovered evaded duties, the White House transshipment report, and now the IOR verification program, CBP is systematically closing the gaps that have allowed non-compliant importers to operate in the shadows.

For compliant importers and brokers, that's actually good news — it levels the playing field against competitors who've been cutting corners. But only if you make sure your own house is in order first.

The September 18 deadline is 18 days away. Pull your Form 5106. Verify every field. Submit your corrections. And if you're a customs broker, start calling your clients today — not Monday, not next week, today.

TariffLens tracks enforcement actions and regulatory deadlines so you don't get blindsided. If you're managing classification and compliance across a portfolio of importers, tools that flag data accuracy issues before CBP does are no longer optional — they're table stakes.

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.