TITLE: CBP IOR Number Enforcement: Key Compliance Deadline for Importers
U.S. Customs and Border Protection (CBP) will begin enhanced enforcement of importer of record data on 18 September 2026.
From that date, CBP may void an importer of record (IOR) number when the associated CBP Form 5106 information is incomplete or inaccurate. A voided IOR number is invalid for any purpose, including entering merchandise into the United States. Shipments can be stopped.
This update matters if you are a UK, EU, Canadian or Australian seller importing goods into the USA. It also matters if your foreign-owned US LLC, marketplace provider, freight forwarder or customs broker is involved in the import process.
Check your IOR records before 18 September
CBP published its Federal Register notice, “Accuracy of Importer of Record Data Submitted to CBP,” on 19 August 2026.
The notice is identified as 91 FR 53627, document 2026-16911, docket USCBP-2026-1024. It implements enhanced enforcement under Executive Order 14411, “Strengthening Customs Enforcement.”
CBP is reviewing the information held for new and existing importers of record. The information must be accurate, complete and directly connected to the IOR.
You should review every entity that imports goods into the USA on your behalf. Do not assume that your broker, freight forwarder or marketplace has maintained the correct records.
Confirm all six required Form 5106 data elements
CBP Form 5106 requires six core data elements:
- Importer name
- IRS EIN, SSN or CBP-assigned number
- Mailing address
- Physical address, if different from the mailing address
- Phone number
- Email address
Each item must be accurate and current. The contact information must belong directly to the importer of record.
Your IOR may be a US LLC, a foreign company, an individual or another eligible entity. The important point is that the entity shown as the importer must match the information submitted to CBP.
This is particularly important where several businesses operate under the same ecommerce group. Check that the legal name, tax identifier and contact details relate to the actual entity named on the customs entry.
Use a genuine physical address
CBP has issued specific instructions about the physical address field.
The physical address must be the actual physical location of the business or individual. It cannot simply be an address used for legal administration or logistics support.
The following addresses cannot be used as a substitute for the IOR’s genuine physical location:
- Registered agent address
- Customs broker address
- Freight forwarder address
- PO box
- Business service centre
- Address belonging to another person or entity
A principal’s home address may be acceptable where it is genuinely associated with the business or individual. The key requirement is that the address must belong directly to the IOR and represent a real physical location.
Example: UK Amazon FBA seller
Imagine a UK ecommerce company selling through Amazon FBA in the United States. Its freight forwarder registered the IOR using the forwarder’s warehouse address or a PO box.
That arrangement now creates a compliance risk. The freight forwarder’s address does not become the UK seller’s physical business location merely because the forwarder receives or manages shipments.
The seller should identify the actual IOR on the relevant entries and ensure that the Form 5106 record uses a qualifying physical address associated with that entity.
Use the IOR’s own email and phone number
CBP will also check the email address and phone number provided on Form 5106.
Both must be valid and belong to the IOR. A customs broker or other third party cannot replace the importer’s contact details with its own.
Review whether your Form 5106 uses:
- An email address controlled by the importer
- A phone number associated with the importer
- Contact details monitored by someone who can respond to CBP
- Information that remains current after business changes
Do not rely on a broker’s shared inbox or operations phone simply because the broker manages customs communications. CBP must be able to identify and contact the importer directly.
This also protects you from missing a CBP notification. CBP will notify the IOR by email at the address most recently submitted.
Check that your broker has a direct power of attorney
A customs broker filing Form 5106 on your behalf must hold a valid power of attorney (POA) executed directly with the IOR.
The POA cannot be arranged through a freight forwarder or another third party. The broker must have direct authority from the entity or individual identified as the importer of record.
Example: EU seller using a broker
An EU seller may have appointed a logistics provider to coordinate shipping to the United States. That logistics provider may then have instructed a customs broker to submit Form 5106.
The seller should confirm that the customs broker has a direct POA with the IOR. A chain of instructions through a freight forwarder does not replace the required direct authority.
Keep a copy of the signed POA and review it when the importing entity, broker or business structure changes. This creates a clearer record of who authorised the filing.
Understand the consequences of an inaccurate record
If CBP identifies incomplete or inaccurate information, it may immediately void the IOR number from 18 September 2026.
The effect is serious. A voided IOR number is invalid for any purpose, including entering imported merchandise into the United States. This can interrupt customs clearance and delay inventory replenishment.
CBP may also take other enforcement action. The Federal Register notice refers to potential exposure under:
- 18 U.S.C. 1001 for intentional false statements or deception
- 31 U.S.C. 3729, the False Claims Act
- 19 U.S.C. 1641 for customs broker penalties and related consequences
These risks make it important to correct inaccurate data before CBP identifies the problem. Do not treat Form 5106 as a one-time administrative form. Its information must remain accurate and up to date.
Review every US-connected importing entity
Marketplace sellers often have more than one entity involved in a shipment.
For example, a UK company may sell the goods, a US LLC may act as the importer, an Amazon fulfilment centre may receive the inventory, and a broker may file the entry. A Shopify seller may use a third-party logistics provider or an IOR-as-a-service arrangement.
Do not assume that the seller, marketplace account holder and importer of record are the same entity.
For each US shipment, confirm:
- Which entity is named as the IOR
- Which IOR number is used
- Which entity owns the EIN or CBP-assigned number
- Which physical location belongs to that entity
- Which email and phone number belong to that entity
- Which broker filed the entry
- Whether the broker has a direct POA
- Whether the same information is used consistently across shipments
This check is especially important for Amazon FBA, Shopify, eBay, TikTok Shop and other international ecommerce operations.
Do not overlook the 366-day IOR inactivity rule
This new Form 5106 enforcement follows a separate CBP change.
From 16 July 2026, CBP will also apply its separate rule on IOR inactivity. Under that rule, an IOR number that has seen no entry activity for 366 consecutive days may be subject to additional verification or inactivation. This means that even if your Form 5106 data is accurate and complete, an extended period without importing could still trigger a compliance review.
If you have multiple IOR numbers across different entities or business lines, check whether any have been dormant for close to a year. If so, consider whether you still need that IOR registered, or whether consolidating activity under a single, compliant record makes more sense for your operations.
Staying proactive on both fronts—accurate Form 5106 data and active IOR usage—will help you avoid unnecessary disruption to your US import supply chain.
