CBP Starts Voiding Importer of Record Numbers on September 18, 2026 for Inaccurate CBP Form 5106 Data — Your Physical Address Cannot Be Your Broker, Freight Forwarder, Registered Agent or a P.O. Box, and the Email and Phone on File Must Be Yours, Not Your Agent's
CBP published a general notice in the Federal Register on August 19, 2026 (91 FR 53627) announcing that it is comprehensively reviewing the CBP Form 5106 data on file for every importer of record, new and existing. Beginning September 18, 2026, if CBP finds that an IOR — or a customs broker filing on the IOR's behalf — failed to provide complete and accurate information, CBP will immediately void the IOR number, rendering it invalid for any purpose including entering merchandise into the United States. The notice singles out three fields: the physical address must be the actual location of the business or individual and cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center, or another party's address; the email address must be valid and belong to the IOR; and the phone number must be valid and belong to the IOR. Brokers and third parties may not substitute their own email or phone for the importer's. This is CBP's first concrete implementation step under Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026. Sellers who set up a US importing entity using their broker's or forwarder's address as the physical address — a common arrangement for non-US-resident sellers — are directly exposed.
Real-World Impact
The voiding is not graduated and carries no cure period in the notice — CBP states it will "immediately void the associated IOR number" on or after September 18, 2026 if the Form 5106 data is inaccurate or incomplete. One wrong field, such as a physical address that is actually the freight forwarder's warehouse, is enough to invalidate the number for every shipment, at which point no entry can be filed under it until CBP reestablishes it. Notice of the voiding goes to the email address most recently on file — so an importer whose email on Form 5106 belongs to a broker rather than to the importer may not learn the number was voided until an entry is rejected at the port.
Key Points
- CBP published the general notice "Accuracy of Importer of Record Data Submitted to CBP" on August 19, 2026 at 91 FR 53627 (FR Doc 2026-16911), implementing Section 2(e) of Executive Order 14411 "Strengthening Customs Enforcement" signed June 3, 2026
- The notice states the enhanced enforcement, "including immediate voiding of IOR numbers with inaccurate information on the CBP Form 5106, will commence on September 18, 2026"
- CBP says it is comprehensively reviewing the CBP Form 5106 information already on file for IORs — this applies to existing importers, not just new registrations
- A voided IOR number is rendered "invalid for any purpose, including entering imported merchandise into the United States," and CBP may also take other enforcement actions
- Physical address: must be the actual physical location of the business or individual, and cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center, or an address of another person or entity — CBP's Form 5106 instructions do allow a principal's home address
- Email address and phone number: both must be valid and belong to the IOR; customs brokers and third parties may not supply their own, or another entity's, in place of the importer's
- CBP Form 5106 requires six data elements: 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
- Customs brokers submitting Form 5106 must hold a valid Power of Attorney executed directly with the IOR — not via a freight forwarder or other third party (19 CFR 111.36(c)(3)) — and must exercise due diligence under 19 CFR 111.29(a) and 111.32
- When CBP voids a number it issues written notice to the email address the IOR most recently submitted, copies the customs broker that last filed entry on the IOR's behalf, and includes instructions for requesting reestablishment
- The notice warns that inaccurate or misleading Form 5106 information is material to a duty-payment obligation and can expose the certifying party to 18 U.S.C. 1001 false-statement liability and False Claims Act liability (31 U.S.C. 3729 et seq.); brokers may face penalties under 19 U.S.C. 1641
- Questions and reestablishment requests go to IORProgram@cbp.dhs.gov with the subject line "Enforcing IOR Accuracy"
- The notice states CBP is separately working to revise importer eligibility regulations under Section 2 of E.O. 14411, with further announcements to come via the CBP website and the Federal Register
What You Should Do Now
- 1Ask your customs broker to pull your current CBP Form 5106 on file and send you the exact values in every field, rather than assuming what was submitted when your IOR number was first created
- 2Verify the physical address on file is your actual business location — if it is your broker, freight forwarder, registered agent, virtual office, business service center, or a P.O. box, correct it before September 18, 2026
- 3Replace any broker-owned or forwarder-owned email address on the form with an address you own and actively monitor, since CBP sends the voiding notice to the most recently submitted email address
- 4Confirm the phone number on file belongs to your business and is answerable, not your agent's line
- 5Confirm your EIN (or SSN or CBP-assigned number) and importer name on file match your current registered entity exactly
- 6Audit your Powers of Attorney — CBP requires the POA to be executed directly between you and the licensed customs broker, not routed through a freight forwarder or other third party
- 7File Form 5106 updates through your broker via ABI, or by email to your assigned Center of Excellence and Expertise, and keep documentation of when each correction was submitted
- 8If your number is voided, contact IORProgram@cbp.dhs.gov with the subject line "Enforcing IOR Accuracy" to request reestablishment, and expect to submit information corroborating your identity
- 9Watch for CBP's forthcoming importer-eligibility rulemaking under Executive Order 14411, which the notice says is still in progress