TITLE: Two US Customs Deadlines Importers Must Act On: Form 5106 Enforcement and the 1 December Disclosure Consultation
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.
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