U.S. Customs and Border Protection’s (CBP) Enhanced Enforcement – Accuracy of Importer of Record’s Information on CBP 5106

U.S. Customs and Border Protection (CBP) has announced enhanced enforcement measures to verify the accuracy of information provided by new and existing Importers of Record (IORs) on CBP Form 5106, the Create/Update Importer Identity Form. These measures are being implemented as part of the Administration’s broader efforts to strengthen customs enforcement.

The information reported on Form 5106 establishes the identity of the Importer of Record and is used by CBP when processing import transactions. CBP is emphasizing that importers and, in some cases, their customs brokers are responsible for ensuring that the information filed with CBP is accurate, complete, and belongs to the Importer of Record.

Information reported on Form 5106 includes:

• Importer name
• IRS Employer Identification Number (EIN)
• Social Security Number (SSN) or CBP-assigned number
• Mailing address
• Physical address, if different from the mailing address
• Telephone number
• Email address
• Optional business information, including business structure, beneficial ownership, and company officers

According to CBP, beginning September 18, 2026, importer numbers associated with inaccurate, incomplete, or unverifiable information may be voided. If an IOR number is voided, it can no longer be used to enter merchandise into the United States, which could result in delays and disruptions to your import operations.

CBP has also noted that individuals certifying Form 5106 information may face civil or criminal consequences for knowingly providing false or misleading information. In addition, because the Importer of Record is the party ultimately responsible for customs obligations, inaccurate information could create exposure under the False Claims Act or other applicable laws. Customs brokers may also be subject to penalties under 19 U.S.C. § 1641 if incorrect information is submitted on behalf of a client.

What We Recommend

We encourage all importers to review their CBP Form 5106 information and confirm that their records are current and accurate. Particular attention should be paid to:

• Legal business name
• EIN or CBP-assigned number
• Business and mailing addresses
• Contact information
• Ownership and officer information, if provided

Keeping this information up to date can help avoid unnecessary import delays, compliance concerns, and potential interruptions to customs clearance activities.

Important Information for Flegenheimer Clients

If you recently established an ACE Portal account to receive IEEPA-related refunds and provided Flegenheimer International with an updated Form 5106, we have already submitted the information received to CBP. We recommend reviewing the information provided to ensure it remains accurate and complete.

If you have not yet submitted an updated Form 5106 to us, or if you would like assistance reviewing your importer information currently on file with CBP, please contact our team at info@flegenheimer.com.

As CBP continues to strengthen enforcement and importer verification procedures, we believe it is important for importers to review their records now rather than wait until a shipment is affected.

Thank you,

Flegenheimer International Team

Resources:

Executive Order 14411

CBP Form 5106

ST&R on CBP to Begin Voiding IOR Numbers for Incomplete or Inaccurate Information

Federal Register Notice