TITLE: U.S. Importer of Record Data: Act Before 18 September 2026 to Avoid Cargo Delays
If you import goods into the United States, check your Importer of Record data now. From 18 September 2026, U.S. Customs and Border Protection (CBP) will immediately void Importer of Record (IOR) numbers linked to inaccurate or incomplete information.
This affects international sellers, non-resident importers, DDP arrangements, Amazon FBA sellers, and businesses using third-party fulfilment centres.
The rule is set out in CBP’s Federal Register notice, 91 FR 53627, published on 19 August 2026. It is the first concrete implementation step under Executive Order 14411, signed on 3 June 2026.
Act before 18 September to prevent cargo delays
A voided IOR number is invalid for all purposes. This includes making entry for imported merchandise.
In practical terms, your cargo may stop at the port because CBP cannot accept an entry using that IOR number. The notice does not provide an automatic cure or grace period before the number becomes invalid.
You may then face:
- Delayed cargo release.
- Additional storage and demurrage charges.
- Missed customer delivery deadlines.
- Disruption to Amazon, Shopify, or marketplace fulfilment.
- Emergency customs and logistics costs.
- Rework with your customs broker and freight forwarder.
Do not assume that a long-standing IOR number is safe. CBP is reviewing both new and existing importer records.
Verify every field on CBP Form 5106
CBP Form 5106, also called the Importer Identity Form, records the information used to identify your business as an IOR.
CBP requires the information to be accurate, complete, current, and directly connected to the IOR.
Check these details:
- Legal name of the importer.
- EIN, SSN, or CBP-assigned importer number.
- Mailing address.
- Physical business address.
- Telephone number.
- Email address.
The physical address is now particularly important.
Use the actual business location
Your physical address must be the actual location of the business or individual acting as the IOR.
It must not be:
- A registered agent’s address.
- A customs broker’s address.
- A freight forwarder’s address.
- A post office box.
- A business service centre.
- A fulfilment provider’s address that is not your business location.
- Another person’s or company’s address.
For example, suppose your UK company imports stock into the United States under a non-resident importer structure. If your Form 5106 lists your U.S. customs broker’s office as the physical address, that information may be defective.
Replace it with the address that genuinely belongs to the IOR. CBP’s notice states that the principal’s home address may be used where it is the physical address associated with the business or individual.
Use importer-owned email and phone details
The email address and phone number must belong to the IOR.
Do not list:
- Your customs broker’s shared inbox.
- Your freight forwarder’s telephone number.
- An accountant’s personal email.
- A former agent’s contact details.
- A fulfilment centre’s customer service number.
This requirement matters because CBP sends a voiding notice to the email address most recently submitted by the IOR.
If that email belongs to a broker, former agent, or inactive employee, you may not receive the warning. You might only discover the problem when a shipment is stopped.
Confirm your customs broker has a direct power of attorney
Your customs broker must hold a valid power of attorney (POA) executed directly with the IOR.
Under 19 CFR 111.36(c)(3), the broker must execute the POA directly with the importer of record. It cannot be executed through a freight forwarder or another third party.
Check that:
- The POA names the correct legal entity.
- The signatory has authority to act for that entity.
- The POA was agreed directly between you and the broker.
- The broker is authorised to submit Form 5106 information.
- Any old or replaced POA has been reviewed.
- Your broker can contact you directly for verification.
A forwarder or logistics provider may introduce you to a broker. It cannot replace the direct legal relationship required between the IOR and the broker.
This is not just an administrative detail. CBP expects brokers to exercise due diligence and avoid transmitting information they know, or should know, is false or misleading.
Understand the liability behind inaccurate data
Incorrect information can create more than a shipment delay.
The Federal Register notice refers to possible consequences under several laws:
- 18 U.S.C. § 1001: knowingly and wilfully making a materially false statement to the U.S. government can lead to fines or imprisonment.
- False Claims Act, 31 U.S.C. § 3729: inaccurate information material to duties or other amounts payable to CBP may create civil liability, including treble damages and applicable civil penalties.
- 19 U.S.C. § 1641: customs brokers may face penalties, suspension, or revocation for certain violations involving inaccurate information, inadequate due diligence, or other customs business failures.
These provisions do not mean that every innocent clerical error will result in prosecution. They do mean that you should correct known inaccuracies promptly and retain evidence showing how you verified your records.
Do not ask a broker or agent to “use an address that works” if it is not your genuine business address.
Check these international seller structures first
Some business models have a higher practical risk of outdated or third-party IOR information.
Non-resident importers
You may be a non-resident importer if your overseas company owns the goods and assumes responsibility for entry into the United States.
Review your records if a U.S. broker created your IOR account years ago. Confirm that the overseas company is correctly identified and that the physical address belongs to that company or its principal, where permitted.
DDP arrangements
Under Delivered Duty Paid arrangements, the overseas seller may remain responsible for import clearance, duties, and taxes.
Do not assume that your logistics provider is the true importer. Identify who is legally acting as the IOR for each shipment and confirm that the Form 5106 information matches that party.
Third-party fulfilment centres
A fulfilment warehouse may store and dispatch your inventory. It is not automatically your business address.
If your IOR record uses the fulfilment centre’s address, ask your customs broker to review the entry structure and update the importer information where necessary.
Ecommerce marketplace sellers
Amazon, Shopify, eBay, Etsy, and other platforms may coordinate fulfilment or shipping. They do not automatically remove your customs obligations.
If you sell from the UK into the United States, review your import records alongside your wider compliance processes. Our guides on Amazon FBA from the UK to the USA and ecommerce shipping and taxation provide useful background.
Complete this pre-18 September checklist
Use the following checklist before the enforcement date.
1. Identify every active IOR number
List each IOR number u
