CBP Voiding Importer of Record Numbers on September 18

Attorney advertising. This alert is general information, not legal advice.

What Importers Need to Know

On August 19, 2026, U.S. Customs and Border Protection published a general notice announcing that beginning September 18, 2026, it will void importer of record (IOR) numbers where the data on file — submitted on CBP Form 5106 — is incomplete or inaccurate. Accuracy of Importer of Record Data Submitted to CBP, 91 FR 53627. A voided number is, in CBP’s words, “invalid for any purpose, including entering imported merchandise into the United States.” Cargo stops. And CBP voids first, then sends written notice to the email address on the 5106, copying the broker that last filed an entry where applicable.

CBP states every data element must belong directly to the importer. The physical address must be the importer’s actual place of business — it “cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center, or an address of another person or entity.” The email address and phone number must likewise belong to the importer. That description fits a very common arrangement: a foreign seller with no U.S. premises whose 5106 carries its broker’s or forwarder’s U.S. address, phone, and inbox.

Highest Risk Profiles

• U.S. importers without a physical office location
• Foreign entities acting as IOR
• DDP sales where the overseas seller is the importer
• Direct-to-consumer and marketplace sellers using third-party fulfillment addresses
• Any IOR number created years ago by a broker and never reviewed since.

One point that is widely misunderstood. A foreign address is not the problem — CBP’s own procedures accept foreign addresses. CBP will not void IOR numbers simply because an importer is located outside of the U.S. An address belonging to someone else is the problem. The fix for most importers is to put their own real information on the form, even where that information is entirely overseas.

What to do next

1. Ask your broker, in writing, for the current 5106 data of record on every IOR number you use. Do not assume it is right.
2. Confirm the physical address, mailing address, email, and phone all belong to the importer — and that someone actually monitors that inbox.
3. Ensure your corporate entity has an actual physical address that CBP can visit. You should have a lease, deed or other agreement in writing to use the property.
4. Confirm the legal name matches the EIN, SSN, or CBP-assigned number on file.
5. Confirm the power of attorney runs directly between the importer and the licensed broker, not through a forwarder or overseas agent. Re-execute if there is any doubt.
6. If you source under DDP terms, ask your suppliers the same questions. Their voided number is your stalled container.

Correct bad data with true information rather than a plausible substitute. The notice flags exposure under 18 U.S.C. § 1001, the False Claims Act, and, for brokers, 19 U.S.C. § 1641.

A larger shift is behind this. The notice implements Executive Order 14411, Strengthening Customs Enforcement (June 3, 2026), which also contemplates minimum tangible domestic asset or bonding requirements for importers, an informal-entry bar for foreign IORs, restrictions on their use of continuous bonds, and CTPAT validation requirements. Foreign-IOR structures that clear the September 18 date may still need to be rethought this fall.

We can help. Lieberman PLLC can audit your Form 5106 data and correct it before the deadline, review your powers of attorney, advise on whether your foreign-IOR structure will survive the coming rulemaking, and manage reestablishment if an IOR number has already been voided. Contact us to discuss your situation.