CBP will void importer numbers over bad Form 5106 data starting September 18

The details

The enforcement is laid out in a Federal Register notice (91 FR 53627) published August 19, 2026, implementing Executive Order 14411, “Strengthening Customs Enforcement,” issued in early June. Supply Chain Dive reported the September 18 start date this week.

What CBP is validating on Form 5106:

• Physical address must be the importer’s actual location. Broker, forwarder, registered agent, PO box and business-service-center addresses are specifically called out as non-compliant.
• Email and phone must belong to the importer, not a broker or third party.
• Tax ID and legal name must match the importer itself.

The obligation sits on the importer of record whether it filed the form itself or a customs broker filed on its behalf, and shippers are responsible for keeping the information accurate after the initial submission. CBP told Supply Chain Dive it is “comprehensively reviewing” contact data already on file.

If a number is voided, it becomes invalid for any purpose, including entering merchandise. CBP will send written notice to the most recently submitted email address explaining the basis for the action and how to request reestablishment; requests go to IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy,” per the C.H. Robinson advisory. A broker with a valid power of attorney may act for the importer. CBP also reserves additional enforcement actions beyond voiding.

The notice is one piece of a broader build-out under the same order: importers must be in “good standing” with CBP within 180 days of the June 3 executive order, and the administration has separately moved on higher penalty floors and crackdowns on foreign IORs.

What buyers should do

• Pull your Form 5106 records now. Ask each broker to confirm the address, email, phone and tax ID on file for every importer number your company uses, and correct anything that points to a third party.
• Fix the master data, not just the filing. Purchasing and trade-compliance systems should carry the importer’s own contact block so broker submissions default to it.
• Verify broker powers of attorney are current, so a broker can respond quickly if a number is voided mid-quarter.
• Assess refund exposure. A valid IOR number is also the ticket to pending tariff-refund programs; Stinson flags that a void could complicate IEEPA refund claims.
• Budget for compliance. KPMG’s André Cruz argued in June that the executive order effectively doubles the return on customs-compliance spend — a useful line if your budget request was cut.

The bigger picture

The voiding regime lands in the middle of the largest customs story of 2026: the refund of tariffs the Supreme Court struck down in February, which is itself gated on having a valid IOR number submitted by end of July (our coverage). It also stacks with other new importer obligations, like the low-value shipment bond rule. The through-line: CBP is converting importer identity into an enforcement lever, and clean customs master data is now a continuity requirement for imports, not a back-office nicety.