Dear client,

U.S. Customs and Border Protection (CBP) is implementing a comprehensive review of CBP Form 5106 information on file for all Importers of Record (IOR) for accuracy, driven by recent Executive Orders to tighten customs enforcement.

Starting September 18, 2026, if CBP determines that an IOR has failed to provide complete and accurate information, they will void the IOR number, halting your supply chain completely and rendering it invalid for any purpose, including entering imported merchandise into the United States.

Where things stand

CBP is establishing a staggered schedule to roll out these enforcement changes. Over the coming months, these measures will heavily impact non-resident IORs and informal entry filings.

• September 18, 2026 — The Identity Clampdown: CBP begins actively voiding non-resident IOR numbers that use improper addresses, have missing data, or use third-party contact information.
• October 1, 2026 — FY2027 Budget Rates Take Effect: The formal entry MPF minimum officially ticks up from $33.58 to $34.58.
• November 30, 2026 — Informal Filings Stop: CBP removes informal entry access for non-resident importers. Low-value shipments (under $2,500) will no longer use the simplified entry track. The flat $2.69 automated informal fee ceases to exist, meaning the base fee instantly leaps to $34.58 per shipment.

What specific data is required

CBP expressly states that the physical address, email, telephone number, and EIN/SSN supplied on the CBP Form 5106 must be complete, accurate, and belong directly to the IOR. Customs brokers or third parties may not supply their own contact info in place of the IOR's.

• Physical address: Must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. Box, or business service center.
• Email address: Must be valid and belong directly to the IOR.
• Phone number: Must be valid and belong directly to the IOR.

What this means for importers

If your IOR is voided during this September cleanup, your supply chain stops completely until you re-register with a valid physical identity. Additionally, providing inaccurate or misleading information could subject the IOR to legal consequences, fines, or liability under the False Claims Act.

Recommended actions (URGENT)

To ensure your IOR number does not get voided, immediate action is required.