If you use an importer of record (IOR) for Amazon FBA inbound shipments, direct-to-consumer ecommerce, or cross-border inventory movements, two US customs developments now require your attention.
Form 5106 enforcement is already live. CBP began voiding inaccurate or incomplete IOR records on 18 September 2026.
Separately, 1 December 2026 is the deadline to comment on proposed supply chain disclosure reforms. The new disclosure framework is not yet final, but it could significantly change the customs records that international sellers must obtain, reconcile and retain.
This article explains what is happening now, what may change next, and how to prepare your business.
Understand the two separate deadlines
Executive Order 14411, “Strengthening Customs Enforcement,” was signed on 3 June 2026. It directs a broad overhaul of the IOR framework, including:
- Restrictions and additional conditions for foreign IORs.
- Higher penalty floors.
- New disclosure and certification requirements.
- A potential “good standing” test.
- Risk-based IOR tiering.
- Revised bonding and eligibility requirements.
The two immediate dates are different:
- 18 September 2026: CBP Form 5106 accuracy enforcement began.
- 1 December 2026: Comments close on CBP’s proposed supply chain visibility framework.
The December date is a consultation deadline. It is not yet the effective date for new mandatory supply chain disclosures.
Fix Form 5106 data before CBP voids your IOR number
CBP’s 19 August 2026 Federal Register notice, “Accuracy of Importer of Record Data Submitted to CBP”, confirms that CBP is reviewing Form 5106 information for new and existing IORs.
CBP Form 5106 records the identity of the importer. It includes information such as:
- Legal importer name.
- EIN, SSN or CBP-assigned number.
- Mailing address.
- Physical business address.
- Phone number.
- Email address.
The information must be accurate, complete and connected directly to the IOR.
A registered agent, customs broker, freight forwarder, business service centre or PO box cannot be used as the importer’s physical address. A broker’s email address or telephone number cannot replace the importer’s own contact details.
Your customs broker must also hold a valid Power of Attorney executed directly with the IOR. A POA arranged through a freight forwarder or another intermediary may not satisfy the requirement.
If CBP decides the data is inaccurate or incomplete, it can immediately void the IOR number. A voided number becomes invalid for any purpose, including entering goods into the United States. This can stop shipments at the border and create additional storage, demurrage and fulfilment costs.
The notice also warns that inaccurate or misleading information may create exposure under the False Claims Act, 31 U.S.C. § 3729, as well as broker penalties under 19 U.S.C. § 1641. Intentional false statements may also create separate legal consequences.
Check the difference between voided and inactive IOR status
CBP also introduced an ACE “Inactive for Entry Purposes” status on 16 July 2026.
Do not assume that an inactive IOR is the same as a voided IOR. In either case, you should:
- Ask your broker to confirm the current status in ACE.
- Identify the reason for the inactive or voided status.
- Correct the Form 5106 information.
- Submit the required reactivation or reestablishment request through the appropriate CBP or ABI process.
- Confirm that the IOR is active before dispatching another shipment.
Keep written evidence of every correction, submission and CBP response. This will help demonstrate that you acted promptly if your customs records are reviewed.
Prepare for the 1 December supply chain disclosure deadline
CBP’s “Heightened Import Disclosures for Supply Chain Visibility” is an advance notice of proposed rulemaking covering 19 CFR Parts 141, 142, 143 and 163.
The notice asks more than 60 questions, including 64 specific questions across three main areas.
1. Collect foreign export documentation
CBP is considering whether US importers should obtain and submit, or retain for inspection, documents that foreign exporters file with their own customs authorities.
Potential documents include:
- Export declarations.
- Commercial invoices.
- Packing lists.
- Certificates of origin.
- Export licences and permits.
- Bills of lading and air waybills.
- Other transport or export records.
The purpose is to help CBP identify discrepancies involving valuation, quantity, classification, origin and possible dual invoicing.
For example, if the value declared to UK, EU, Canadian or Australian customs differs from the value used in the US entry summary, CBP may want importers to explain and evidence the difference.
Start asking suppliers now:
- Which export documents are created?
- Who holds the original records?
- Can the documents be provided in English or translated?
- How quickly can your supplier respond to a CBP request?
- Can the documents be matched to a specific shipment, SKU and entry?
2. Replace limited manufacturer identification data
CBP is also considering reforms to the Manufacturer Identification Code, or MID.
The current MID can provide limited information and may not always identify a unique manufacturer. CBP is considering collecting the manufacturer’s full legal name, physical address and additional business identifiers.
The notice also asks whether global business identifiers should become mandatory. These may include:
- D-U-N-S numbers.
- Global Location Numbers.
- Legal Entity Identifiers.
- Altana IDs.
- Foreign tax identifiers.
CBP is also considering whether online marketplaces should be identified as parties in the supply chain. This may be relevant to sellers using Amazon, Shopify, TikTok Shop, eBay, Etsy or WooCommerce where different entities manufacture, sell, ship and fulfil the goods.
3. Use technology to trace goods and detect transshipment
The third area focuses on technology and supply chain tracing.
CBP is examining the use of AI-driven tools to verify origin, detect illegal transshipment and identify inconsistencies in production data. It is also asking whether CTPAT requirements should include:
- Enhanced tracing technology.
- Cybersecurity and data-integrity controls.
- Restrictions on logistics platforms considered a national-security risk.
- Additional trade facilitation benefits for members sharing visibility data.
These proposals are not final rules. However, they show that customs compliance is moving towards a more connected model where product, supplier, logistics and financial records must support one another.
Expect more scrutiny from CTPAT-validated brokers
CBP’s August 2026 CTPAT alert places additional responsibility on CTPAT-validated customs brokers serving foreign IORs.
Brokers are expected to vet clients on matters including:
- Legal identity.
- Ownership and business affiliations.
- US assets.
- Previous import and compliance history.
- Ability to pay duties, fees and penalties.
- Classification, valuation and origin processes.
- Supply chain structure.
A broker that fails to perform the required checks may face penalties, audits or removal from CTPAT. The current enforcement direction also includes a 50% minimum penalty floor, with no mitigation for repeat offenders in the relevant circumstances.
For UK, EU, Canadian and Australian sellers, this means your broker may request more corporate documents and customs evidence before accepting future entries.
Confirm whether your broker is CTPAT-validated. If you use a foreign IOR, ask how the broker is meeting the new vetting expectations. If you are changing brokers, complete onboarding early rather than waiting until a shipment is already in transit.
Worked example: a UK seller loses access to its IOR number
Consider a UK-owned ecommerce business that sends inventory to Amazon FBA in the United States.
The company uses a customs broker and a freight forwarder. When the original Form 5106 was filed, the physical address recorded for the IOR was the forwarder’s warehouse address. The email and phone number also belonged to the forwarder.
After 18 September 2026, CBP reviewed the record and voided the IOR number because the address and contact details did not belong directly to the importer.
The seller then had to:
- Confirm the correct legal and physical address.
- Submit updated Form 5106 information.
- Execute a direct POA with the customs broker.
- Provide corporate identity documents.
- Request reestablishment of the IOR number.
- Wait for confirmation before releasing new entries.
In this illustrative example, three inbound pallets were delayed for five business days. The seller incurred approximately $1,200 in storage and handling costs, paid expedited freight charges to protect an Amazon replenishment deadline, and lost several days of sales due to unavailable stock.
The exact cost will vary by shipment and port. The lesson is consistent: a Form 5106 error can become an operational and cash-flow problem very quickly.
Complete this pre-December compliance checklist
Use the following checklist before 1 December:
- Audit Form 5106 data. Confirm the legal name, EIN, physical address, email and phone belong directly to the IOR.
- Review all POAs. Ensure each customs broker has a valid POA signed directly with the IOR.
- Check ACE status. Confirm whether the IOR is active, inactive or voided.
- Confirm broker credentials. Check CTPAT validation and ask how foreign IOR vetting is performed.
- Map your supply chain. Record the manufacturer, seller, exporter, shipper, marketplace, logistics provider and final consignee.
- Collect export records. Ask suppliers for declarations, invoices, packing lists, origin documents, permits and transport records.
- Reconcile customs and bookkeeping records. Match entry values, duty, freight, landed cost and inventory records to your accounting system.
- Diarise 1 December 2026. Decide whether your business should submit comments through Regulations.gov under docket USCBP-2026-1058.
- Review Form 5472 obligations. If you filed Form 7004 for the 2025 tax year, check the extended 15 October 2026 deadline.
Connect customs records with Form 5472 and your accounts
Customs compliance does not operate separately from tax compliance.
A foreign-owned US corporation or foreign-owned US disregarded entity may need to file Form 5472 when it has reportable transactions with a foreign or domestic related party. The IRS instructions confirm that Form 5472 must be attached to the relevant Form 1120 or pro forma Form 1120.
For calendar-year filers with a valid extension, the extended deadline is 15 October 2026.
Form 5472 penalties can be significant. The IRS instructions state that a failure to file, or a substantially incomplete filing, may result in a $25,000 penalty. Additional penalties may apply if the failure continues after IRS notification.
Your bookkeeping should therefore reconcile:
- Inventory purchases.
- Related-party payments.
- Freight and duty.
- Customs valuation.
- Amazon or marketplace settlements.
- Intercompany funding.
- Inventory transfers.
- US LLC or corporation transactions.
This is where structured ecommerce bookkeeping UK businesses often need becomes important. Your ecommerce accountant UK team should be able to connect sales, inventory, customs, VAT or sales tax and US reporting records rather than treating each filing as a separate task.
How Sterlinx Global can support your compliance system
Sterlinx Global operates as a Global Tax Compliance Suite for international businesses. You provide the underlying data, and we complete compliance work on an ongoing basis through structured bookkeeping, tax calculations, indirect tax filings and year-end reporting.
Our support can include:
- US accounting and compliance for eligible entities.
- Bookkeeping and transaction reconciliation.
- Form 5472 and related filing support.
- Customs-duty and landed-cost record reconciliation.
- UK, US, Canada, Australia and Ireland compliance coverage.
- Modular VAT, GST and Sales Tax services where required.
If your IOR details need reviewing, your Form 5472 deadline is approaching, or your customs records do not match your accounts, contact us to discuss the next compliance steps.
Frequently asked questions
Is 1 December 2026 the date when the new CBP disclosure rules begin?
No. It is the deadline for comments on the advance notice of proposed rulemaking. CBP may use the feedback to develop a future proposed rule.
Does Form 5106 enforcement apply only to new importers?
No. CBP is reviewing Form 5106 information for existing and new IORs.
Can I use my customs broker’s address on Form 5106?
No. The physical address must belong directly to the IOR and represent the actual business or individual location. A broker, forwarder, registered agent or PO box address is not suitable as the physical address.
What happens if CBP voids my IOR number?
The number becomes invalid for entering imported merchandise. You should correct the underlying information and follow CBP’s reestablishment process before attempting further entries.
Should I wait for the final supply chain rules before collecting documents?
No. Begin mapping your supply chain and collecting export records now. Early preparation will reduce disruption if new requirements are introduced.
Can customs data affect Form 5472?
Yes. Customs payments, inventory transfers, related-party transactions and import costs may affect the records needed for accurate US reporting. Keep customs paperwork reconciled with your bookkeeping throughout the year.
