CBP to Scrutinize 5106 Filings

CBP Enhances Verification of Importer of Record Information

On August 19, 2026, U.S. Customs and Border Protection (CBP) issued a Federal Register document regarding the accuracy of Importer of Record (IOR) information submitted through the CBP Form 5106 process.
The document states that CBP is implementing enhanced enforcement procedures to verify the accuracy of information provided by new and existing Importers of Record on CBP Form 5106, consistent with Executive Order 14411. These enhanced verification procedures will become effective September 18, 2026.

Importers of Record and their customs brokers should ensure that all information submitted on the CBP Form 5106—typically filed electronically by the customs broker—is complete and accurate. If CBP determines that information is inaccurate or otherwise does not meet its requirements, CBP may immediately void the IOR number and take additional enforcement action.

Information CBP Will Verify

CBP has identified three key areas of focus:

1. Physical Address
The physical address provided for the IOR must be the actual physical location of the business or individual. It may not be a registered agent, customs broker, freight forwarder, P.O. box, business service center, or the address of another person or entity.

2. Email Address
The email address submitted must be valid and belong to the IOR. Customs brokers or other third parties may not provide their own email address, or the email address of another person or entity, in place of the IOR’s email address.

3. Telephone Number
The telephone number provided must be valid and belong to the IOR. A number that is not associated with the IOR should not be submitted. Customs brokers or other third parties may not provide their own telephone number, or the telephone number of another person or entity, in place of the IOR’s telephone number.

What Happens After September 18, 2026?

Beginning September 18, 2026, if CBP determines that the information provided on a Form 5106 is inaccurate or incomplete, CBP may void the importer’s number and issue a written notice of action to the email address associated with the most recent Form 5106 submission. The notice will provide information regarding the steps required to reestablish the IOR number.
Questions regarding the IOR program may be directed to CBP at IORProgram@cbp.dhs.gov.

Recommended Action

If you have not reviewed or updated your CBP Form 5106 information recently, we recommend contacting your customs broker before September 18, 2026, to confirm that the physical address, email address, and telephone number currently on file are accurate, valid, and directly associated with the Importer of Record.
Taking this step in advance can help avoid potential disruption to importing privileges and ensure compliance with CBP’s enhanced verification requirements.

John Boomhover
Director of Compliance & Customs Services
CV International, Inc.