2026-08-20
U.S. Customs and Border Protection said it will begin voiding importer of record numbers on September 18 if it finds that the identity data tied to those accounts is inaccurate or incomplete, a move that raises the compliance stakes for companies that bring goods into the United States.
In a notice published Wednesday in the Federal Register, CBP said it is starting “enhanced enforcement procedures” to verify the accuracy of information submitted on Form 5106, the document used to create or update an importer identity. The agency said the review applies to both new and existing importers of record, known as IORs, as well as customs brokers who file the form on an importer’s behalf.
The notice marks one of the first concrete implementation steps tied to Executive Order 14411, “Strengthening Customs Enforcement,” which President Trump signed on June 3. CBP said the order directs the Department of Homeland Security to confirm that active importers of record comply with applicable regulations and disclosure rules. The agency also said it is taking broader steps to revise importer eligibility regulations, guidance and policies under that order and existing statutes.
The immediate issue for importers is practical. If CBP determines that an importer or a broker acting for that importer has failed to provide complete and accurate information on Form 5106, the agency said it will void the IOR number. Once voided, the number becomes invalid for any purpose, including entering imported merchandise into the United States.
That could create operational problems across consumer sectors, including beverages. Importers of wine, beer and spirits depend on valid importer of record numbers to move products through customs, and a voided number could potentially lead to delays, shipment holds or an inability to clear goods until the record is restored. For businesses working with seasonal orders, limited releases or time-sensitive inventory, even a short interruption could complicate distribution plans.
CBP said importers, or brokers filing on their behalf, must make sure that all required information on the form is accurate, complete and belongs directly to the importer of record. The required data includes the importer’s name, an Internal Revenue Service employer identification number, Social Security number or CBP-assigned number, mailing address, physical location address if different, phone number and email address. The form also allows several optional fields, including information about company structure, beneficial ownership and corporate officers.
The agency devoted particular attention to basic contact and identity details that it said are often used to verify the importer. The physical address, CBP said, must be the actual location of the business or individual. It cannot be a registered agent’s address, a customs broker’s address, a freight forwarder’s address, a P.O. box, a business service center or the address of another person or entity. An email address must be valid and belong to the importer, not to a broker or some other third party. The same standard applies to the phone number.
For beverage companies that use outside compliance firms, customs brokers or logistics providers, that distinction matters. Many importers rely on intermediaries to handle filings, but the agency is making clear that a broker’s contact details cannot be substituted for the importer’s own information on the identity form. The importer’s records, CBP said, must identify the importer itself.
The notice also puts customs brokers on direct notice. CBP said brokers must exercise due diligence before transmitting information and should not submit data they know, or should know, is false, misleading or unverified. A broker that files Form 5106 for a client must also hold a valid power of attorney executed directly with the importer of record, as required by CBP regulations. The agency said that power of attorney may not be arranged through a freight forwarder or another third party.
CBP tied the policy shift to enforcement priorities that go beyond paperwork. In the notice, the agency said accurate importer information is necessary to identify the party responsible for duties and to enforce federal laws covering forced labor, rules of origin, country-of-origin marking, intellectual property, revenue collection and product safety. The agency said accurate IOR data is also important to national security, foreign policy and the economy.
The notice carries legal risk as well as business risk. CBP said a person certifying Form 5106 may face fines or imprisonment under 18 U.S.C. 1001 for intentionally making a false statement or committing deception or fraud on the form. The agency also said inaccurate or misleading information can be material to an obligation to pay money to CBP, which could expose an importer or associated individuals to liability under the False Claims Act and other laws. Customs brokers that submit inaccurate or invalid information may face broker penalties or other consequences under federal customs law.
CBP said it is already reviewing Form 5106 information on file for importers of record. Starting September 18, when the enhanced enforcement begins, the agency said it will immediately void any IOR number associated with inaccurate or incomplete information. It also said it may take other enforcement actions when appropriate.
If an IOR number is voided, CBP said it will send written notice to the email address most recently submitted by the importer. The notice will explain the basis for the action and provide instructions for requesting that the number be reestablished, including the information the importer must provide to corroborate its identity. If applicable, CBP said it will also copy the customs broker that most recently filed an entry for that importer.
Questions about the enforcement effort and requests to restore a voided number may be sent to IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy,” according to the notice. The agency identified Anita Rivera, branch chief of the Revenue Enforcement Branch in CBP’s Trade Modernization Division, as the contact for further information.
For importers that have not revisited their Form 5106 data in years, the notice amounts to a warning to do so now. That includes checking whether listed addresses still match the actual business location, whether phone and email contacts belong to the importer, whether tax identification details are correct, and whether the broker on file has a valid power of attorney executed directly with the importer. In sectors with layered supply chains, including alcohol imports, those details can be easy to overlook until a shipment is at the border.
CBP said further public announcements on importer eligibility rules and related enforcement changes will be made on its website and through other public channels, including future Federal Register publications, as it continues to implement the executive order.