US Customs and Border Protection will begin voiding importer of record numbers on September 18, 2026 when the identifying data on file is wrong, stale or borrowed from somebody else. The agency set out the policy in a general notice published in the Federal Register on August 19, 2026, carried at 91 FR 53627 under document number 2026-16911.
The mechanism is blunt. If CBP concludes that the information on an importer’s CBP Form 5106 is inaccurate or incomplete, it may void the associated importer of record (IOR) number immediately. A voided number is invalid for any purpose, including the entry of merchandise into the United States.
There is no phase-in and no announced grace period beyond the 30 days between publication and the effective date. CBP has said it is reviewing existing Form 5106 records comprehensively, not only new applications, which puts accounts opened years or decades ago inside the review population.
For retail and e-commerce, the exposure is concentrated in exactly the setups that became normal practice after the de minimis exemption ended: foreign sellers importing into the United States through brokers, freight forwarders and registered agents whose addresses ended up on the government form.
In short
- Effective September 18, 2026, CBP may immediately void an importer of record number when CBP Form 5106 data is inaccurate or incomplete, per the Federal Register notice published August 19, 2026.
- Six data elements are in scope: importer name, tax identification number, mailing address, physical location address, telephone number and email address.
- Third-party contact data is the main defect: the physical address must be the importer’s actual business location, and the phone and email must belong to the importer rather than a broker, forwarder or registered agent.
- A voided number stops entries at once, leaving cargo held while demurrage and per diem accrue, with reestablishment handled by email to CBP’s IOR program.
- This is the first concrete step under Executive Order 14411, “Strengthening Customs Enforcement”, signed June 3, 2026, which also contemplates tougher bonding and disclosure rules for foreign importers of record.
What exactly did CBP announce?
The notice is administrative rather than regulatory in form. CBP did not amend a rule through notice-and-comment procedure; it published a general notice describing how it intends to enforce an existing requirement that importer identification data be accurate and current.
That distinction matters less than it sounds. The obligation to file and maintain CBP Form 5106 already sits in the customs regulations. What changes on September 18 is the consequence attached to a defect, which moves from correspondence and follow-up to immediate voidance of the number used to make entry.
CBP framed the action as part of the initial implementation of Executive Order 14411. Law firm analyses published in the days after the notice, including commentary from Clark Hill on August 20 and from Livingston International on August 19, read it the same way: a first, cheap, high-leverage enforcement move ahead of the heavier rulemaking the order requires.
Who the notice binds
Two populations are addressed. Importers of record carry the primary duty to ensure the data they submitted is accurate, complete and updated when circumstances change. Licensed customs brokers carry a parallel due diligence duty when they file or update Form 5106 on a client’s behalf.
Broker exposure is the part most easily missed. A broker who submits identification data without a valid power of attorney executed directly with the importer, or who inserts its own address to smooth a filing, is squarely inside the conduct the notice targets. Penalty exposure for brokers sits alongside the importer’s own risk under federal false statement statutes and the False Claims Act.
Why the timing looks deliberate
Thirty days is short for a compliance clean-up that touches finance, legal, logistics and the broker relationship. It is also, in practice, the last quiet window before peak season entries begin arriving in volume for the 2026 holidays.
An importer that discovers a defect in late October, with containers on the water, is in a materially worse negotiating position than one that fixes the record in early September. Nothing in the notice suggests CBP is unaware of that sequencing.
Which data fields does CBP actually check?
CBP Form 5106, the Create/Update Importer Identity Form, is the record that ties a legal entity to the number used on entry documents. It is short, it is rarely revisited after account opening, and it is now the trigger for the most abrupt sanction in routine customs administration.
Six elements are named as the mandatory set subject to verification. Three of them are the ones that generate almost all real-world defects.
| Form 5106 field | What CBP expects | Common defect that triggers voidance |
|---|---|---|
| Importer name | The exact legal entity name that matches the tax identification record | Trade name or DBA filed instead of the registered legal name |
| Tax identification | EIN, SSN or a CBP-assigned number, matching the named entity | Number belonging to a parent, affiliate or predecessor entity |
| Mailing address | An address the importer controls and monitors | Broker or forwarder mailbox that the importer never reads |
| Physical location address | The actual location of the business acting as importer of record | Registered agent, P.O. box, business service center or broker office |
| Telephone number | A number answered by the importer | Broker or freight forwarder switchboard listed as the importer line |
| Email address | A mailbox owned by the importer itself | Broker, forwarder or consultant address used as the address of record |
The physical address problem
CBP has been explicit that the physical address must reflect where the importer actually operates. Registered agent addresses, customs broker offices, freight forwarder locations, post office boxes, business service centers and addresses belonging to unrelated entities are all called out as unacceptable.
This is not a marginal formatting complaint. For a large share of foreign-owned importing entities, the registered agent address is the only US address that ever existed. Company formation services supply it by default, and it flows into every subsequent filing, including Form 5106.
The practical test an importer should apply is simple: if a CBP officer drove to the address on the form, would they arrive at premises the importer occupies or controls? If the answer is a law firm lobby, a mail drop or a broker’s counter, the record is defective under the notice.
The email and phone problem
Contact data carries a second function under this notice, because it is the channel through which CBP delivers the voidance decision itself. Notice of voidance is sent to the most recent email address on the Form 5106, with a copy to the associated customs broker.
An importer whose email of record belongs to a broker who no longer handles its account, or to a departed employee, may not learn its number has been voided until a shipment is stopped. The reestablishment clock effectively starts without the importer knowing.
The identity chain behind the tax number
The stated target of the wider enforcement push is shell entities and nominee structures: paper importers of record with no assets, no premises and no ability to answer for a duty bill. Verifying that the name, tax number and physical presence describe one real business is how CBP proposes to find them.
That framing explains why ownership information appears in the compliance advice even though it is not one of the six form fields. CBP is checking whether the entity behind the number is substantive, and mismatches between the named entity and its tax records invite exactly that question.
What happens when an importer of record number is voided?
The operational answer is that entry capability stops. A voided IOR number cannot be used to enter merchandise, so filings that depend on it fail from the moment of voidance rather than at the next renewal or review point.
Cargo already moving does not pause politely. Containers on the water, freight in air terminals and trucks at land borders continue to arrive and then sit, because the entity named to make entry no longer has a usable number.
Storage economics take over from there. Demurrage accrues on containers held at the terminal, per diem accrues on equipment not returned, and warehousing or chassis costs attach depending on mode. None of those charges pause while the importer works through reestablishment.
How reestablishment works
CBP’s notification email carries instructions for reestablishing the number. The published route is an email to IORProgram@cbp.dhs.gov using the subject line “Enforcing IOR Accuracy”, accompanied by corroborating documentation that establishes the importer’s identity and its actual place of business.
No service standard for turnaround has been published. That is the single largest planning unknown in the notice, because the cost of a voidance is almost entirely a function of how many days elapse before the number works again.
What a holiday-season voidance would cost
The cost is easier to frame as a range than a number, because it depends on mode, port and contract terms. A single ocean container held past its free time in a congested US port can accrue four-figure daily charges once demurrage and per diem stack, and importers running multiple containers a week compound that quickly.
Retailers with dated inventory face a second layer: seasonal goods that clear in December have a fraction of the margin they would have had in October. For apparel, decor and toys, a two-week hold near peak can convert a full-price sell-through plan into a markdown plan.
Why is CBP doing this now?
The proximate cause is Executive Order 14411, “Strengthening Customs Enforcement”, signed on June 3, 2026. The order directs the Department of Homeland Security to tighten the machinery around who is permitted to import into the United States, naming undervaluation, misclassification, illegal transshipment, forced labor sourcing and the use of shell companies as the practices it targets.
Within 180 days of signature, which falls at the end of November 2026, the order requires DHS to revise importer eligibility regulations, guidance and policies. Analyses of the order describe an implementation track staged across 45, 90 and 180 days rather than a single deadline.
Read against that timetable, the Form 5106 notice is the first deliverable that required no rulemaking at all. CBP already had the authority to insist on accurate identification data. What it added was a consequence.
The harder rules still to come
The eligibility work contemplated by the order is more consequential than the current notice. Reported elements under consideration include minimum domestic asset or bond coverage thresholds, expanded business and beneficial ownership disclosure, declaration of anticipated import volumes, and financial responsibility standards that an importer must satisfy before it may make entry.
Foreign importers of record are singled out. According to analyses of the order, foreign IORs would face higher minimum bond coverage, would be restricted from using a continuous bond unless CBP is satisfied that revenue is protected and compliance assured, and would be barred from filing the informal entries commonly used for low-value shipments.
That last item is the one with the sharpest edge for cross-border e-commerce. Informal entry is the cheap lane, and losing it converts a large volume of small parcels into formal entries with the documentation and brokerage cost that implies. Our earlier coverage of CBP’s Entry Type 13 mail entry test starting September 22 describes the parallel build-out on the postal side.
The revenue backdrop
Customs duty collections have moved from a rounding error in federal receipts to a headline line item. Reported figures put US customs duty collections at roughly $79bn in calendar 2024, rising to about $264bn in calendar 2025 after successive tariff rounds.
When the duty rate on a given import is 10%, a paper importer that disappears before paying costs the government 10 cents on the dollar. When effective rates run several times higher, the same evasion is proportionally more attractive and proportionally more expensive to tolerate. Enforcement intensity has followed the money.
Who is most exposed to a voided number?
The risk is not evenly distributed. A domestic retailer importing on its own EIN, from its own head office address, with its own accounts payable mailbox on the form, has close to no exposure. The defect population sits at the other end: entities whose US footprint is thin by design.
| Importer profile | Typical Form 5106 setup | Defect risk | Fix before September 18 |
|---|---|---|---|
| US retailer or brand importing directly | Own EIN, head office address, internal trade compliance mailbox | Low | Confirm the address is current after any relocation or entity restructuring |
| Foreign brand selling into the US | Registered agent address supplied at incorporation | High | Substitute a real US operating address or reconsider who acts as IOR |
| Marketplace seller using a third-party fulfillment center | Fulfillment provider or broker contact data on the form | High | Replace third-party phone and email with the seller’s own |
| Supplier shipping DDP to a US buyer | Foreign supplier named as IOR, broker address on file | High | Reconfirm who is legally the importer and whose data is filed |
| Small importer with a dormant legacy account | Data filed years ago, never revisited | Medium to high | Pull the record and verify all six fields against current facts |
Delivered duty paid arrangements
DDP terms concentrate the problem because they push importer of record status onto a party that is, by construction, offshore. The foreign supplier or its nominated agent takes on the customs obligation, and the address that lands on Form 5106 is frequently the broker’s, because there is no other US address in the file.
Buyers who assume DDP insulates them from customs risk should re-read the arrangement. If the nominated IOR’s number is voided mid-shipment, the goods stop regardless of who bears the duty under the commercial contract.
Marketplace sellers and fulfillment centers
Selling through Amazon, Shopify, eBay or Etsy does not transfer customs obligations from the seller to the platform. The seller who is importer of record remains the party CBP holds responsible for the accuracy of its identification data, whatever the storefront relationship looks like.
The pattern that creates defects here is administrative rather than evasive. A seller sets up importing, the fulfillment provider or broker completes the paperwork, and the provider’s address and contact details end up on the form because they are the ones handling the goods. Nobody revisits the record until something breaks.
Cross-border platform sellers already under pressure
For platforms built on high-volume, low-value cross-border flow, this lands on top of an existing cost stack. The duty economics have already tightened, as our reporting on PDD Holdings meeting the EU parcel duty in its second quarter results set out.
Identification enforcement adds a different kind of risk to that picture. Duty is a margin problem that can be priced. A voided IOR number is an availability problem that cannot, because the goods simply do not clear.
How did the end of de minimis multiply the exposure?
Before August 29, 2025, shipments valued under $800 could enter free of duty under the de minimis exemption, and the volume that moved that way was enormous. The exemption’s elimination for all countries pushed every one of those parcels into formal or informal entry with duty, tax and fee assessment attached.
That change did more than raise costs. It multiplied the number of transactions in which somebody has to be named as importer of record, and it pulled thousands of small foreign sellers into a regime they had never previously touched.
Many of them solved the problem the fastest way available: a US entity formed through a service provider, a registered agent address, and a broker who filled in the forms. That is precisely the profile CBP’s notice describes as defective.
The postal channel
Postal flows have been converging on the same treatment. Reporting indicates the prepaid duty threshold for postal shipments moved to $2,500 as of July 24, 2026, and CBP’s Entry Type 13 electronic informal entry test for mail shipments valued at $2,500 or less commences September 22, 2026 and runs indefinitely.
Four days separate the IOR voidance date from the Entry Type 13 launch. Importers running mail-channel volume face both changes inside a single week, with holiday inbound already building.
What should importers do before September 18?
The work is unglamorous and mostly clerical. It is also the cheapest customs project available this year, measured against the cost of a peak-season hold.
- Pull every active IOR number. Larger groups frequently discover numbers tied to dormant subsidiaries, acquired entities or legacy divisions that still appear on entries.
- Read the record, do not assume it. Retrieve the actual data CBP holds rather than the data the compliance team believes was filed.
- Test the physical address. If it is a registered agent, P.O. box, business service center, broker or forwarder location, it fails.
- Reclaim the phone and email. Both must resolve to the importer, and the email must be a monitored mailbox rather than a personal address of a departed employee.
- Verify the tax identification chain. The EIN, SSN or CBP-assigned number must match the exact legal entity named on the form.
- Check every broker power of attorney. Brokers filing on an importer’s behalf need a POA executed directly with that importer.
- Model the disruption. Identify which shipments would be stranded if the number went dark for a week, and where the resulting demurrage would land.
How to update the record
Three routes are available. An importer with ACE Secure Data Portal access can update Form 5106 data directly through the portal. An importer waiting on portal access can ask its broker to run an Importer/Bond Query to retrieve what CBP currently holds. A revised Form 5106 can also be submitted to the importer’s assigned Center of Excellence and Expertise, through ABI or by email.
Portal enrollment is itself a lead-time item. An importer that has never activated ACE access should start that process rather than assume it can self-serve a correction in the days before the deadline. The official notice text is available on the Federal Register for compliance teams that want the primary language.
What to tell the broker
Brokers are inside the enforcement perimeter, not outside it, so the conversation is a shared one. The useful questions are narrow: what data do you currently have on file for us, whose address and contact details did you submit, and do you hold a current power of attorney executed by our entity.
A broker that inserted its own contact data years ago to speed an account opening is not being obstructive by admitting it. It is surfacing the exact defect the notice was written to catch, at the only point in the calendar when fixing it is cheap.
How does this fit the wider 2026 customs build-out?
The Form 5106 notice is one line in a year of unusually dense customs activity. Reading it in isolation understates how much administrative surface importers are being asked to absorb between now and the end of the year.
On the tariff side, Section 301 forced labor duties of 10% and 12.5% across 60 economies took effect on July 24, 2026, and Section 338 duties of 50% on certain Canadian goods took effect in late August after negotiations failed. Our coverage of the Canada tariffs going live as talks collapsed traces how quickly that timeline moved.
On the rate-setting side, the Commerce Department’s Bureau of Industry and Security has continued expanding Section 232 derivative product coverage, with a comment window on 14 additional goods closing August 27, 2026. We covered that proposed derivative expansion and its August 27 deadline earlier this month.
The refund track is moving the other way
Running against all of this is the refund machinery created after the Supreme Court held, on February 20, 2026, that the President lacks authority to impose tariffs under the International Emergency Economic Powers Act. More than $170bn in IEEPA-related duties had been collected before that ruling.
The Consolidated Administration and Processing of Entries (CAPE) system is how those refunds flow. Reported figures as of July 31, 2026 put submitted CAPE declarations above 75,000, validated entries liquidated without IEEPA tariffs at 17.69 million, and potential and certified refunds accepted for processing at roughly $128.68bn.
That money is already showing up in retail results, most visibly where refunds were recycled into price. Our reporting on Walmart directing a $2.9bn tariff refund into price cuts set out how one retailer chose to deploy it.
Why the CAPE delay compounds the identification problem
CBP postponed the launch of CAPE Phase 3, which addresses finally liquidated entries that paid IEEPA duties, from its scheduled August 20 date. The postponement was reported as indefinite, with no replacement date announced.
The two threads intersect at the importer of record number. Refunds under CAPE run back to the importer of record or its agent that paid the duty, which means the same identification record that CBP is now scrutinising sits underneath a claim on cash.
An importer whose number is voided while a Phase 3 claim is pending has a problem in both directions: goods that cannot enter and a refund attached to a record CBP has flagged as defective. Neither the notice nor CBP’s refund guidance addresses that interaction directly.
What is still unclear?
Several material questions are unresolved, and importers planning around this should treat them as open rather than assume favourable answers.
Turnaround time. No service standard has been published for reestablishing a voided number. The difference between a two-day and a two-week restoration is the difference between an inconvenience and a peak-season failure.
Warning practice. The notice describes immediate voidance, but does not state whether CBP intends to contact importers about suspect data before acting. Commentary is split on whether the agency will in practice issue queries first, and importers should not rely on receiving one.
Volume. CBP has not said how many records it expects to review or void. Broker commentary references a population of several hundred thousand importers that have paid duties, which gives a sense of scale but not of enforcement intensity.
Interaction with bonds. Whether a voided number affects an existing continuous bond, and how surety providers will treat it, has not been addressed. That question becomes sharper if the eligibility rulemaking under Executive Order 14411 introduces bond thresholds later this year.
What would signal escalation
Three observable developments would indicate that this is the opening move rather than a one-off tidy-up. The first is a published proposed rule on importer eligibility before the 180-day mark at the end of November 2026.
The second is any restriction on informal entry for foreign importers of record, which would hit cross-border parcel economics directly. The third is the appearance of bond or domestic asset thresholds, which would convert a data-accuracy exercise into a capital requirement.
What is the practical read for retail?
For most established US retailers, this is a records check that should take a compliance analyst a day and produce nothing alarming. The exposure is real but narrow, and it concentrates in acquired entities and dormant numbers rather than the main importing account.
For cross-border sellers, the calculus is different. The combination of an identification regime that assumes a genuine US operating presence, a proposed bonding regime that assumes domestic assets, and a possible informal entry restriction points toward a structural question rather than a form-filling one: whether acting as your own importer of record into the United States remains viable at small scale.
Some sellers will answer that by building real US presence. Others will shift to arrangements where a substantive US party takes importer of record status, accepting the margin cost that comes with it. Both are strategic responses, and both take longer than the 24 days remaining before September 18.
What none of them can be is a last-minute fix. The importers who come through this cleanly are the ones who pull their records this week.
Frequently asked questions
When exactly does the new CBP policy take effect?
September 18, 2026, which is 30 days after the Federal Register notice was published on August 19, 2026. From that date CBP may immediately void importer of record numbers when Form 5106 data is found to be inaccurate or incomplete.
What is CBP Form 5106?
It is the Create/Update Importer Identity Form, the record that links a legal entity to the importer of record number used on customs entries. It captures the importer’s name, tax identification number, mailing address, physical location address, telephone number and email address.
Can I use my customs broker’s address on Form 5106?
No. CBP has stated that the physical address must be the actual location of the business acting as importer of record. Broker offices, freight forwarder locations, registered agent addresses, P.O. boxes and business service centers are all identified as unacceptable.
What happens to my cargo if my IOR number is voided?
A voided number is invalid for entering merchandise, so entries stop immediately. Shipments already in transit or awaiting clearance are held while reestablishment proceeds, and demurrage, per diem and storage charges continue to accrue during that period.
How will I know if my number has been voided?
CBP sends notice to the most recent email address on file for the Form 5106, with a copy to the associated customs broker. This is why an email address that belongs to a third party or a departed employee is a compounding risk rather than a technicality.
How do I get a voided importer number reestablished?
The published route is an email to IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy”, supported by documentation corroborating the importer’s identity and actual place of business. CBP has not published a turnaround time for restoration.
Does this apply to foreign companies importing into the US?
Yes, and foreign importers of record face additional measures under Executive Order 14411. Reported elements include higher minimum bond coverage, restrictions on using a continuous bond, and a bar on filing the informal entries commonly used for low-value shipments.
Does selling on Amazon or Shopify change my customs obligations?
No. Marketplace and platform relationships do not transfer importer of record duties. If your entity is named as importer of record, you remain responsible for the accuracy of the identification data CBP holds.
How does this relate to Executive Order 14411?
The order, signed June 3, 2026 and titled “Strengthening Customs Enforcement”, directs DHS to revise importer eligibility rules within 180 days. The Form 5106 notice is described as one of the first concrete implementation steps under it, ahead of the heavier rulemaking still expected.