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CBP will void importer of record numbers over bad Form 5106 data from 18 September 2026
Starting 18 September 2026, US Customs and Border Protection will void an importer of record number outright if the underlying Form 5106 data is incomplete or inaccurate — a hard, dated rule change with no announced grace period, implementing an executive order signed in June.
Datos clave
- Alcance: All imported goods. This is an importer-account requirement, not a commodity-specific rule — it applies equally to every importer of record clearing goods through US Customs and Border Protection.
- From 18 September 2026, CBP will void an importer of record (IOR) number if it determines the importer, or a broker acting on its behalf, gave incomplete or inaccurate Form 5106 data.
- A voided number is invalid for any purpose, including entering merchandise into the United States — this can stop every shipment an importer has in transit.
- The six mandatory Form 5106 elements: importer name, EIN/SSN/CBP-assigned number, mailing address, physical location address (if different), phone number, and email address.
- CBP says it will provide instructions for reestablishing a voided number, but has not yet published what that process involves.
What the rule actually says
CBP published a general notice on 19 August 2026, Accuracy of Importer of Record Data Submitted to CBP, implementing Executive Order 14411 (Strengthening Customs Enforcement, signed 3 June 2026). Beginning 18 September 2026, if CBP determines that an importer of record — or a customs broker acting on the importer's behalf — has failed to provide complete and accurate information on CBP Form 5106, CBP will void the importer number. A voided number is invalid for any purpose, including entering merchandise into the United States, and CBP may take further enforcement action on top of the voiding itself.
The six mandatory Form 5106 elements are: importer name; IRS EIN, SSN, or CBP-assigned number; mailing address; physical location address, if different from the mailing address; phone number; and email address. CBP states it will provide instructions for seeking reestablishment of a voided importer number, but has not published what that process looks like — there is no established reestablishment path to point to today.
Where this actually bites
Food importers are particularly exposed, because the fields most likely to have gone stale are exactly the ones CBP is checking: a physical address that's actually a broker's or a third-party logistics provider's rather than the importer's own; a phone number or email nobody has updated since the account was first opened; or an EIN filed under a predecessor entity after a corporate restructure. None of these are unusual, and none currently trigger any warning before the account becomes unusable.
Qué hacer
- 1.Pull your current Form 5106 record and confirm all six mandatory fields are accurate and current — name, EIN/SSN/CBP number, mailing address, physical location address, phone, and email.
- 2.Confirm the physical location address on file belongs to the importer itself, not a broker's or 3PL's address used as a stand-in.
- 3.Check that your customs broker's power of attorney reflects your current corporate name and structure, especially after any merger, acquisition or entity change.
- 4.Designate a named person who can respond quickly if CBP queries your Form 5106 file, since a voided number stops every shipment in transit under it.
- 5.Complete this review well before 18 September 2026 — there is no published grace period and no confirmed reestablishment process if a number is voided.