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CBP now voids importer of record numbers over bad Form 5106 data, from 18 September 2026
Since 18 September 2026, US Customs and Border Protection voids an importer of record number outright if the underlying Form 5106 data is incomplete or inaccurate. The rule implements an executive order signed in June, and CBP's notice also describes the route back: a written notice of the voiding, then a reestablishment request by email.
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.
- Since 18 September 2026, CBP voids 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, so it 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 send written notice of the voiding to the importer's most recently submitted email address, copying the last filing broker where applicable, with the basis for voiding and how to request reestablishment.
- Reestablishment requests and questions go to IORProgram@cbp.dhs.gov with the subject line Enforcing IOR Accuracy. The importer, or a broker holding a valid power of attorney, may contact CBP.
What the rule 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). From 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 voids 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. The physical address must be the actual physical location of the business, not a registered agent, customs broker, freight forwarder, P.O. box, business service center, or the address of another person or entity. The email address and phone number must be valid and belong to the importer.
What happens after a number is voided
CBP's notice says it will send a written notice of the voiding to the email address the importer most recently submitted, stating the basis for voiding, and will copy the customs broker that last filed entry for the importer where applicable. That notice is to say how to request reestablishment, including what information must be submitted to corroborate the importer's identity. The Federal Register notice does not itself list that information.
Requests for reestablishment, and questions about a voided number, may be sent to IORProgram@cbp.dhs.gov with the subject line Enforcing IOR Accuracy. The importer, or a customs broker with a valid power of attorney, may contact CBP. The notice does not state how long reestablishment takes.
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 is 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. The notice describes written notice after a number is voided, not a warning beforehand, so the time to check these fields is before CBP does.
Update, 1 October 2026
The 18 September 2026 start date in the notice has now passed, so the enforcement described here is in effect on the notice's terms. This piece was revised on 1 October: the first version said no reestablishment process existed, but the notice describes one (written notice of the voiding, then a request to IORProgram@cbp.dhs.gov). We have not found a CBP statement on how many numbers have been voided.
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, 3PL's or business service center's address used as a stand-in, and that the email address and phone number are the importer's own.
- 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 contacts you about your Form 5106 file, since a voided number stops every shipment in transit under it.
- 5.If a number is voided, watch the email address on file for CBP's written notice, then request reestablishment at IORProgram@cbp.dhs.gov with the subject line Enforcing IOR Accuracy, using the identity information the notice asks for.