US Customs and Border Protection (CBP) have issued the initial step, Accuracy of Importer of Record Data Submitted to CBP which took effect September 18, 2026. As of that date, CBP began an enhanced review of Importer of Record (IOR) accounts and voided any IOR numbers it determined had been provided with incomplete or inaccurate information.
This represents the initial step following US President Donald Trump’s Executive Order of June 3, 2026 titled “Strengthening Customs Enforcement” directing the Department of Homeland Security (DHS) and CBP to undertake a broad overhaul of the rules governing importation into the United States.
If CBP determines that the information provided on a CBP Form 5106 is inaccurate or incomplete, CBP may, as of September 18, 2026, immediately void the associated IOR number.
In the event an IOR number has been voided, the importer will not be able to import goods into the U.S..
- CBP will issue a written notice of this action to an IOR to the email address the IOR most recently submitted to CBP, that notifies the IOR of the basis for voiding the IOR number. If applicable, CBP will copy the customs broker that last filed entry on behalf of the IOR when issuing the notice.
- The notice will include information on how to request reestablishment of the IOR number, including what information must be submitted to CBP to corroborate the identity of the requesting IOR.
- The IOR, or a customs broker with a valid Power of Attorney, may contact CBP at IORProgram@cbp.dhs.gov with questions regarding a voided IOR number.
Importers into the U.S. should ensure their information on file with US Customs is current and valid, via a CBP Form 5106 – Create/Update Importer Identity Form.
A CBP Form 5106, contains the below minimum mandatory information:
- Importer name
- IRS Employer Identification Number (EIN), Social Security Number (SSN), or CBP-assigned importer number
- Mailing address
- Physical location address, if different from the mailing address
- Telephone number
- Email address
Importers must take note of the below legal requirements
Physical Address: The physical address provided for the IOR must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center, or an address of another person or entity.
Email Address: The email address submitted must be valid and belong to the IOR. Customs brokers or third parties may not supply their own email address, or the email address of another person or entity, in place of the IOR’s email address.
Phone Number: The phone number provided must be valid and belong to the IOR. Numbers not associated with the IOR should not be submitted. Customs brokers or third parties may not supply their own phone number, or the phone number of another person or entity, in place of the IOR’s phone number.
US importer clients of Universal Logistics are advised to provide a completed CBP Form 5106 so that we may file on your behalf with US Customs and ensure the existing information is correct and up to date.
For more information, contact Brian Rowe, Director – Customs Compliance & Regulatory Affairs.
