CBP Steps Up Importer of Record Enforcement Beginning September 18

U.S. Customs and Border Protection (CBP) is increasing enforcement of Importer of Record (IOR) information maintained through CBP Form 5106, Create/Update Importer Identity Form, as part of the implementation of Executive Order 14411, Strengthening Customs Enforcement.

Effective September 18, 2026, CBP has announced that if it determines an importer’s Form 5106 information is inaccurate or incomplete, CBP will immediately void the associated Importer of Record number. Once voided, the IOR number will be invalid for any purpose, including entering imported merchandise, until CBP completes the reestablishment process.

Importers should review the information currently maintained with CBP and confirm that it remains accurate and up to date, including:

• Legal company name

• Physical and mailing addresses

• Telephone number and email address

• EIN or other taxpayer identification information

• Business structure, beneficial ownership, and company officer information, where applicable

Importers with access to the ACE Secure Data Portal should review the importer information currently reflected in their ACE account and confirm that it remains accurate and up to date. 

Importers should also ensure that the email address maintained with CBP is actively monitored. CBP will use the most recently reported email address to provide written notice of actions affecting an IOR number.

Executive Order 14411 also directs CBP and the Department of Homeland Security to implement broader importer vetting, recurrent review, good-standing requirements, and additional importer eligibility standards. 

Juno Customs Solutions recommends that importers review their Form 5106 information before the September 18, 2026, enforcement date. Importers needing assistance reviewing or updating their CBP Form 5106 should contact their Juno Customs Solutions representative.