Why Did CBP Void My Importer of Record Number? The September 18, 2026 Form 5106 Enforcement
By Ruta Riley, Founding Partner, One Lex Partners LLC. Published September 17, 2026. This article is general information, not legal advice.
If your entries suddenly began rejecting, or your broker told you your importer of record number is no longer valid, this is CBP's new Form 5106 enforcement. Beginning September 18, 2026, CBP will immediately void an importer of record number when the identity information on the importer's Form 5106 is inaccurate or incomplete. A voided number cannot be used for any purpose, including entry, so shipments stop until CBP reestablishes it. Short answers are in the FAQ at the bottom.
The most exposed groups are foreign sellers whose broker or forwarder registered the number using its own contact details, and U.S. entities registered at their agent's address.
What happened
On June 3, 2026, the President signed Executive Order 14411, Strengthening Customs Enforcement. CBP's first step under the order is a review of the identity data on file for every importer of record, new and existing. The data sits on CBP Form 5106, the importer identity form filed under 19 C.F.R. § 24.5: legal name, EIN, SSN, or CBP-assigned number, mailing address, physical address, phone number, and email address. A record that fails the review gets its number voided immediately, starting September 18, 2026.
Why CBP voided your number
CBP is checking three things:
The physical address must be the actual location of the business or individual. A registered agent's address, a customs broker's or freight forwarder's address, a P.O. box, or a business service center does not qualify.
The email address and phone number must belong to the importer, not to the broker or forwarder that set up the account.
A broker who filed the form must hold a power of attorney signed directly by the importer, not passed through a forwarder.
What a voided number means
A voided number cannot make entry. Cargo on the water arrives with no party able to enter it, which means storage charges, missed deliveries, and eventually general order. CBP sends the voiding notice to the most recent email address on file, states the basis, explains how to request reestablishment, and copies the broker that last filed entry. If that email address was never yours, the first sign will be a rejected entry.
How to get the number reestablished
CBP gives three channels:
Reestablishment requests and questions: IORProgram@cbp.dhs.gov, subject line “Enforcing IOR Accuracy.”
Corrections to the Form 5106 data: through your broker in the Automated Broker Interface.
Or corrections by email to your assigned Center of Excellence and Expertise. If no Center has been assigned, use the Center matching the tariff classification of your highest valued commodity.
Do it in this order. Read the voiding notice for the specific basis and the identity documents CBP asks for. Correct every field, not only the flagged one, because a record with one remaining bad field can be voided again. Keep the submission, its date, and CBP's response.
Before you file anything: two checks
First, check who certified the original form and whether they knew the information was wrong. The certifying party is exposed under 18 U.S.C. § 1001 for intentionally false statements, and importer identity data is material to the duty obligation, which brings the False Claims Act into play. A knowingly false filing should be corrected with counsel, sequenced with a prior disclosure analysis, not through a casual account update that documents the problem without resolving it.
Second, check whether the entity on your entries should be there at all. If the record listed a broker's address because the company has no U.S. presence, or the importing entity exists only on paper, accurate data entry will not fix it. The underlying questions are whether the entity has the right to make entry as owner or purchaser under 19 U.S.C. § 1484, and whether a nonresident importer meets the resident agent and surety requirements of 19 C.F.R. § 141.18. Both are covered in our companion piece on who can serve as the importer of record.
Can I just get a new number instead?
No. A new entity's Form 5106 is certified under the same accuracy rules and reviewed the same way, now with a prior voiding in the history. CBP is also revising importer eligibility rules under the executive order, and the direction is more vetting, not less. Fix the record on the entity that actually imports.
If you are the customs broker
The requirements reach brokers too: due diligence over client information (19 C.F.R. § 111.29(a)), no transmitting information you know or should know is false or misleading, including unverified information (§ 111.32), and powers of attorney executed directly with the importer (§ 111.36(c)(3)). Submitting invalid Form 5106 data carries penalty exposure under 19 U.S.C. § 1641. Client records built on forwarder-supplied contact details need correction now.
Frequently asked questions
How do I find out why CBP voided my importer number?
CBP sends a written notice stating the basis to the most recent email address on the importer's Form 5106, with a copy to the broker that last filed entry. If no notice arrived, check whose email address was on file, then contact CBP at IORProgram@cbp.dhs.gov with the subject line Enforcing IOR Accuracy.
Can I still import while my number is void?
No. A voided number is invalid for any purpose, including making entry, until CBP reestablishes it.
How do I correct my Form 5106 information?
Through the Automated Broker Interface or by email to your assigned Center of Excellence and Expertise. If no Center has been assigned, use the Center that aligns with the tariff classification of your highest valued commodity. Keep proof of the submission and CBP's response.
My broker's address was on my Form 5106. Is that really a problem?
Yes. CBP's notice states the physical address must be the actual location of the business or individual, and specifically excludes registered agent, broker, forwarder, P.O. box, and business service center addresses. The email and phone must belong to the importer as well.
Does this apply to foreign importers of record?
Yes. The requirements apply to all importers of record, and nonresident importers are among the most affected because their numbers were often set up by brokers or forwarders using their own contact details. A foreign importer must also satisfy the separate nonresident entry requirements, including a resident agent for service of process and a bond from a resident surety.
If your cargo is stopped
If your number was voided, you need three things: the number restored, the record corrected without creating new exposure, and a structure that will not trigger this again. If you have any questions, contact us at onelexpartners.com
