Your Ability to Import Could Be Switched Off in Nine Days
On September 18, 2026 — nine days from today — U.S. Customs and Border Protection will begin immediately voiding importer of record (IOR) numbers whose underlying data is inaccurate or incomplete. A voided IOR number is invalid for every purpose, including making entry, which means cargo stops at the port with no advance warning. This is not a future rule or a proposed rulemaking. CBP published a general notice in the Federal Register on August 19, 2026, announcing enhanced enforcement of IOR data accuracy, and the notice is one of the first concrete implementation steps of Executive Order 14411 — applying to both new and existing IORs. If your Form 5106 information is stale, routed through a third party, or simply wrong, your IOR number is the thing CBP will cancel first. Everything else — your shipments, your clearances, your supply chain — stops with it.
What Is CBP Form 5106 and Why Does It Matter
CBP Form 5106 is the Create/Update Importer Identity Form — the document every company or individual must file to obtain an Importer of Record number. Without a valid IOR number, you cannot make entry into the United States. The form ties your legal identity to every customs entry you file, every duty you owe, and every compliance obligation you carry as an importer. The information on that form helps CBP identify who is legally responsible for imported merchandise, duties, taxes, fees, records, and compliance obligations.
The form requires six core data elements: importer name, IRS EIN or SSN, mailing address, physical location address, phone number, and email address. For years, many importers filed this form once and never revisited it — sometimes with a customs broker's address listed as their own, or a broker's email in the contact field. Under the new enforcement approach, those long-accepted practices are now treated as defects.
The Executive Order Behind the Enforcement
On June 3, 2026, President Trump signed Executive Order 14411, Strengthening Customs Enforcement. Section 2(e) directs the Secretary of Homeland Security to confirm that active importers of record are compliant with all applicable regulations and disclosures. CBP's response was swift and comprehensive. CBP states that it is comprehensively reviewing the CBP Form 5106 information on file for all importers of record. The scale of that review is significant. Earlier this year, CBP deactivated roughly 4.8 million importer of record accounts that had not filed an entry within the preceding year. The September 18 enforcement date targets the accounts that remain active but carry bad data.
What CBP Is Treating as a Defect
Several data conditions that were previously tolerated in practice are now explicitly defects under the enhanced enforcement framework.
Physical address
CBP has specifically highlighted the importance of verifying the physical business address — this must be the actual physical location of the Importer of Record and cannot be the address of a registered agent, customs broker, freight forwarder, P.O. box, business service centre, or another person or entity. If your Form 5106 shows your customs broker's office address, that is a defect.
Email address and phone number
The email address and phone number must belong to the IOR. Broker or forwarder contact information in those fields no longer passes. CBP will send void notifications to the email address on file, so if that email is a broker inbox your team never monitors, you may never receive the warning before your IOR is canceled.
Power of attorney
Brokers must execute the power of attorney directly with the IOR under 19 CFR 111.36(c)(3). A POA obtained through a freight forwarder does not satisfy the regulation. The practical exposure for brokerages is significant: a brokerage that populated its own address, email, or phone across hundreds of client records has hundreds of potential defects, each of which CBP now treats as unverified information transmitted to the agency.
Legal Consequences Beyond a Voided Number
CBP also reserves the right to pursue additional enforcement actions. The notice further warns that inaccurate information may expose importers and associated individuals to additional consequences. Those consequences are not minor. Submitting false information on CBP Form 5106 can result in federal criminal liability under 18 U.S.C. 1001 (false statements — fines and/or imprisonment), False Claims Act liability under 31 U.S.C. 3729 (because IOR data is tied to duty obligations), and broker penalties under 19 U.S.C. 1641. Even where the error was unintentional — a stale address, an old email — the enforcement mechanism is immediate and the burden to correct falls entirely on the importer.
What to Do Before September 18
The corrective window is short and the steps are straightforward.
Pull your actual Form 5106 record
Pull the actual data on file. Do not rely on what you believe was submitted. Request the current Form 5106 record through your customs broker or the ACE Secure Data Portal and review the physical address, mailing address, email address, phone number, and identification number as CBP sees them today.
Verify every field belongs directly to your organization
Confirm the physical address is your actual business location. Confirm the email address is one your team owns, actively monitors, and controls. Confirm the phone number is a direct line to your organization. Confirm the EIN or SSN matches your legal entity exactly. If your CBP Form 5106 data is out of date, incomplete, or associated with a third party rather than your organization directly, your IOR number is at risk.
Submit corrections promptly
Corrections can be submitted via the Automated Broker Interface (ABI) or by emailing your Center of Excellence and Expertise (CEE). Starting September 18, 2026, an IOR number can be voided immediately — and this is not limited to new importers: CBP has said it is reviewing the data behind every IOR number on file, whether the account was opened last month or decades ago.
Verify your power of attorney chain
If you use a licensed customs broker, confirm that the power of attorney was executed directly between your organization and the broker — not routed through a freight forwarder or intermediary. Brokers must execute the power of attorney directly with the IOR under 19 CFR 111.36(c)(3). A POA obtained through a freight forwarder does not satisfy the regulation.
What Happens If Your IOR Is Voided
If CBP determines that Form 5106 is inaccurate or incomplete, CBP will as of September 18, 2026, immediately void the associated IOR number and will issue a written notice of this action to an IOR to the email address the IOR most recently submitted to CBP. That notification will include the basis for the voiding and instructions for what identity documents to submit. If a number is voided under this review, CBP's notice states to write IORProgram@cbp.dhs.gov with the subject line Enforcing IOR Accuracy. Until the IOR number is reinstated, no entries can be filed and no merchandise can legally enter the United States under that account.
According to the notice, CBP is taking initial steps to implement Executive Order 14411, and broader revisions to importer eligibility regulations, policies, and guidance are under development. This enforcement action is a beginning, not an endpoint.
How ASR Can Help
ASR WorldWide Express is a licensed freight forwarder (FMCSA MC# 1667345-B, DOT# 4286843, SCAC AZCB) coordinating import shipments through trusted licensed customs broker partners. If you are unsure whether your Form 5106 data is accurate, or if you need to verify that your power of attorney arrangements are compliant with the September 18 requirements, our team can connect you with the right resources and help you assess your documentation before the deadline.
Call us at +1 786 373 3003 or email shipping@asrwe.com. With nine days remaining before CBP begins voiding IOR numbers, the time to act is right now — not after your next shipment is stranded at the port.
Important Disclaimer
This article is for informational purposes only and does not constitute legal or customs compliance advice. Customs regulations, enforcement priorities, and form requirements can change rapidly. Importers should consult a licensed customs broker or qualified trade attorney to evaluate their specific Form 5106 data, power of attorney arrangements, and compliance posture before the September 18, 2026 enforcement date.
