Starting September 18, 2026, U.S. Customs and Border Protection will immediately void the importer numbers of any company with inaccurate information on file. If your IOR number is voided, you cannot import goods into the United States — full stop. Here’s what you need to know and what to do before the deadline.
The Executive Order Behind This
On June 3, 2026, President Trump signed Executive Order 14411 — “Strengthening Customs Enforcement.” Section 2(e) directs the Department of Homeland Security to verify that all active Importers of Record (IORs) are compliant with applicable regulations and disclosures.
CBP’s response is direct: a comprehensive review of every CBP Form 5106 on file. Any IOR — or customs broker acting on an IOR’s behalf — that has submitted incomplete or inaccurate information faces immediate consequences starting September 18.
What Is CBP Form 5106?
CBP Form 5106 is the Create/Update Importer Identity Form — the document every company or individual must file to obtain an Importer of Record (IOR) number. Without a valid IOR number, you cannot make entry into the United States. The form requires six core data elements: importer name, IRS EIN or SSN, mailing address, physical location address, phone number, and email address.
What “Accurate” Actually Means — The Specific Rules
Physical Address
Must be the actual physical location of the business or individual. The following are not acceptable: registered agent address, customs broker or freight forwarder address, P.O. Box, business service center (UPS Store, virtual office), or any address belonging to another entity.
Email Address
Must be a valid email that belongs directly to the IOR. Customs brokers and freight forwarders may not substitute their own email address — even if they’re the ones filing the form. This matters especially because CBP will send void notices to the email on file.
Phone Number
Must be a valid number belonging to the IOR. A broker’s or forwarder’s phone number cannot be used as a substitute.
EIN / SSN
The tax identification number must belong directly to the IOR — not a parent company, affiliated entity, or third party.
What Happens If Your IOR Number Is Voided
This is not a warning letter or a fine — it’s an immediate shutdown of your import activity. A voided IOR number is invalid for any purpose, including making entry of imported merchandise into the United States.
CBP will send written notice to the email address on file. The notice will explain the basis for the void and provide instructions for requesting reestablishment. To request reestablishment, contact CBP at IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy.”
Special Rules for Customs Brokers
If you’re a licensed customs broker filing Form 5106 on behalf of a client, these rules carry serious professional obligations:
- Valid POA required — Must be executed directly with the IOR. POAs obtained via a freight forwarder or other third party are not valid for this purpose.
- Due diligence is mandatory — You cannot transmit information you know — or should know — is false or unverified.
- Your license is at risk — Brokers submitting inaccurate information may face penalties under 19 U.S.C. 1641, in addition to the IOR’s number being voided.
The Legal Stakes
CBP made the legal consequences explicit. Submitting false information on CBP Form 5106 can result in federal criminal liability under 18 U.S.C. 1001 (false statements — fines and/or imprisonment), False Claims Act liability under 31 U.S.C. 3729 (because IOR data is tied to duty obligations), and broker penalties under 19 U.S.C. 1641.
Your Action Checklist — Do This Before September 18
- Pull your current CBP Form 5106 and verify every field is accurate and current
- Confirm your physical address is your actual business location — not a P.O. box, registered agent, or service center
- Verify your email is one you own and actively monitor — CBP void notices go here
- Confirm your phone number belongs to the IOR, not a broker or forwarder
- Validate your EIN/SSN matches the IOR entity exactly
- Review your POA (brokers) — confirm it’s executed directly with the IOR, not through a third party
- Submit corrections promptly via ABI or by emailing your Center of Excellence and Expertise (CEE)
This Is Just the Beginning
CBP’s notice explicitly states that “further public announcements will be made” as it continues implementing E.O. 14411. The September 18 IOR accuracy enforcement is the first wave — additional revisions to importer eligibility regulations, guidance, and policies are coming. Importers with clean, accurate records now will be better positioned for whatever follows.
FreightClear Can Help
If you’re unsure whether your CBP Form 5106 information is accurate and compliant, Freightclear licensed customs brokers can review your importer profile and help you file corrections before the September 18 deadline. We’ve been handling U.S. customs compliance for over 38 years.
Contact FreightClear for a compliance review, or use the FreightClear.ai platform to manage your import documents and get instant answers to customs questions.
Source: U.S. Customs and Border Protection, General Notice — Executive Order 14411 Implementation (August 2026). Questions: IORProgram@cbp.dhs.gov
