GDLSK | CBP Announces Enhanced Enforcement of IOR Requirements and Voiding of Importer Numbers for Inaccurate Form 5106 Information

U.S. Customs and Border Protection has issued a General Notice announcing enhanced enforcement procedures to verify the accuracy of information submitted on CBP Form 5106.  Significantly, the initiative applies not only to new importer applications, but also to the Form 5106 information already on file for existing importers.  The notice was published on August 19, 2026, and states that enforcement will begin 30 days after publication (September 18, 2026).

Beginning on that date, CBP states that it will immediately void an IOR number if it determines that the importer or its customs broker failed to provide complete and accurate Form 5106 information.  A voided IOR number will be invalid for all purposes, including making entry of imported merchandise, and CBP may pursue additional enforcement action where it deems appropriate.  In practical terms, inaccurate importer information could prevent entry processing and disrupt an importer’s shipments until the IOR number is reestablished.

The notice places particular emphasis on the accuracy of the following Form 5106 information:

• Physical address: The address must be the importer’s actual physical location.  It cannot be the address of a customs broker, freight forwarder, registered agent, unrelated person or entity, P.O. box, or business-service center.  A principal’s home address may qualify where it is genuinely the address associated with the business.
• Email address: The email must be valid and belong to the importer.  A broker, freight forwarder, or other third party may not substitute its own email address.
• Telephone number: The telephone number must be valid and associated with the importer, rather than the broker or another third party.
• Importer identification information: The importer’s legal name, EIN, SSN, or CBP-assigned number, as applicable, must be accurate and belong to the importer.

Accordingly, all importers should review their CF 5106 information and verify the information against reliable business or identity records, and promptly correct outdated or inaccurate CF 5106 data.

If CBP voids an importer number, it will send written notice to the most recent email address provided for the importer.  The notice will state the basis for the action and explain how the importer can request re-establishment by providing information corroborating its identity.  The importer, or a broker holding a valid POA, may contact CBP at IORProgram@cbp.dhs.gov using the subject line “Enforcing IOR Accuracy.”

Compliments of GRUNFELD DESIDERIO LEBOWITZ SILVERMAN & KLESTADT LLP (GDLSK) – a member of the EACCNY