Policy Update: CBP Can Void an Inaccurate Importer Number

Since September 18, 2026, US Customs and Border Protection can immediately void an importer of record (IOR) number whose CBP Form 5106 information is inaccurate or incomplete — including a physical address, email address or phone number that does not belong to the importer. A voided IOR number is invalid for any purpose, including entering merchandise into the United States.

What Changed, in Plain Terms

CBP published a general notice on August 19, 2026 implementing Executive Order 14411, “Strengthening Customs Enforcement,” signed on June 3, 2026. The notice takes aim at one specific thing: whether the information identifying an importer is real.

Every importer of record has a CBP Form 5106 (Create/Update Importer Identity Form) on file, filed by the importer or by a broker through the Automated Broker Interface. CBP is now reviewing those forms; where the information is inaccurate or incomplete, it voids the associated IOR number — immediately.

This is not a fine, a warning letter or a request for correction. It removes the number that lets you import.

The Three Fields That Decide It

The notice is unusually specific about what “accurate” means:

• Physical address — it must be the actual physical location of the business or individual. It cannot be a registered agent, a customs broker, a freight forwarder, a P.O. box, a business service center, or the address of another person or entity. The address associated with the business may be the principal’s home address.
• Email address — it must be valid and belong to the IOR. Brokers and third parties may not substitute their own email address, or anyone else’s.
• Phone number — the same rule: it must be valid and belong to the IOR, not to the broker or another party.

One pattern CBP is explicitly clearing is a service provider supplying its own contact details on your form for convenience. Your broker must also hold a power of attorney executed directly with you, not through a forwarder or another intermediary.

Why a Voided Number Hurts More Than a Penalty

A penalty is a cost. A voided IOR number is an operational stop: no entry can be made under it, which means cargo cannot be entered for consumption while the problem is unresolved. If it happens mid-shipment, the goods sit.

The exposure does not stop at the void. Because IOR data identifies the party liable for duties, CBP treats inaccurate information on the form as material to an obligation to pay money to the government — the basis for the notice’s reference to the False Claims Act. Knowingly false statements also carry potential liability under 18 U.S.C. 1001, and brokers can face penalties under 19 U.S.C. 1641.

For a US importer, the practical lesson is straightforward: the identity data on your customs file is not administrative trivia. It is the foundation of your ability to import.

This Is One Piece of a Much Larger Rewrite

The September 18 action is the first visible step of Executive Order 14411, and the order itself directs far more. Its deadlines run mostly within 90 to 180 days of June 3, 2026, and the specific rules will arrive through further CBP notices and rulemaking. What has been directed:

• Financial standing: importers should expect requirements to maintain a minimum level of tangible domestic assets, bonding, or both, and an increase in the minimum required bond coverage.
• Foreign IORs: the order directs prohibiting foreign importers of record from filing informal entries for low-value shipments, and for formal entries bars them from relying on a continuous bond unless CBP permits it, while requiring CTPAT validation or the use of a CTPAT-validated licensed customs broker.
• “Good standing”: CBP is directed to define and require good standing based on compliance history and payment of customs liabilities, and to bar importers who are not in good standing from importing or designating a broker to act on their behalf.
• The IOR registry: inactive IOR numbers are to be removed, active ones verified, and importers placed into risk-based tiers based on compliance history, audits and enforcement results.
• Vetting: enhanced and recurring vetting for brokers, freight forwarders, custodians of bonded merchandise, IOR affiliates and foreign IORs.
• Disclosure: heightened certification and disclosure, including supply chain and production details such as model or style numbers and composition, plus foreign tax and global business identifiers.
• Penalties: a mitigation floor of not less than 50 percent of the assessed penalty absent exceptional circumstances, a minimum liquidated damages floor, and no mitigation for repeat offenders.

The direction is consistent: CBP wants every entry traceable to an identifiable, accountable, financially responsible importer. The three mistakes in our DDP mistakes guide are the same theme from the importer’s side.

Where This Risk Usually Sits

In practice the problems are not exotic. They look like borrowed contact details, an address that belongs to whoever handled the filing, an identifier transcribed years ago and never revisited, or a power of attorney signed through an intermediary rather than directly with the importer. Individually each looks minor — until the day the number stops working, taking your ability to enter cargo with it.

The importers who never meet this problem share one habit: the identity information on the customs file is reconciled with the entry paperwork before cargo moves, not after a hold. What an entry actually contains is set out in our guide to US customs clearance, and DDP explained covers how responsibility splits when another party files on your behalf. Customs clearance services is where that reconciliation sits when it is handled end to end.

If Your Number Has Already Been Voided

CBP issues written notice to the email address the IOR most recently submitted, and copies the broker that last filed entry. The notice states the basis for the voiding and how to request reestablishment.

Reestablishment follows the procedure CBP sets out in the notice, and in practice it runs through the party that files entries on your behalf. The official notice is 91 FR 53627, and the underlying order is Executive Order 14411. Because this is an active enforcement program, verify current requirements against the Federal Register and CBP before relying on any summary — including this one.

Frequently Asked Questions

Does this apply to importers who already have an IOR number?

Yes. The notice covers both new and existing importers of record. CBP is reviewing the Form 5106 information already on file, not only future submissions.

Will CBP warn me before voiding my number?

The notice describes voiding as immediate upon CBP’s determination, with written notice issued to the importer afterward and copied to the last filing broker. Treat it as something to prevent rather than something to appeal.

Can I use my customs broker’s address or email on the form?

No. All three must belong directly to the importer of record. A broker may file the form on your behalf but may not substitute its own details.

What counts as an acceptable physical address?

The actual physical location of the business or individual — not a registered agent, broker, forwarder, P.O. box or business service center. Per the form instructions, the principal’s home address can qualify.

How does this affect DDP shipments?

A DDP service covers freight, clearance, duty and delivery, but it does not change who is legally the importer of record or the accuracy of the identity data filed with CBP. That is why the party answering this question for you should be able to name the entity declared as importer of record on your entries — and show you the entry documents afterwards.