CBP Starts Voiding Faulty IOR Numbers: What Importers and Freight Forwarders Need to Do Now
Updated September 22, 2026 | U.S. Customs & Trade Compliance
CBP officers inspect cargo containers at a U.S. port. Photo: Jerry Glaser / U.S. Customs and Border Protection (public domain).
U.S. Customs and Border Protection (CBP) has started voiding importer-of-record (IOR) numbers when the information on file is wrong or incomplete. Once an IOR number is voided, it cannot be used to file a U.S. customs entry. Cargo can sit at the port even if the goods, HS codes, and origin documents look fine.
The tighter review took effect on September 18, 2026. It applies to both existing importers and new registrations.
What changed
On August 19, 2026, CBP published a Federal Register notice (91 FR 53627) saying it would verify CBP Form 5106 data for all importers of record. Form 5106 is the Create/Update Importer Identity Form. It is how a company gets an IOR number and keeps that identity current in CBP systems.
This is not a new form and not a new data field. The duty to keep 5106 data accurate already existed. The change is enforcement: CBP is checking records already on file, and a bad record can now be voided on the spot.
The notice implements the first stage of Executive Order 14411, “Strengthening Customs Enforcement,” signed in June 2026.
CBP port operations at Los Angeles / Long Beach. Official DHS photo by Jetta Disco (public domain).
What CBP is checking on Form 5106
CBP expects every field to be accurate, complete, and tied to the importer itself:
- Legal company name
- EIN / tax ID (or SSN / CBP-assigned number)
- Mailing address
- Actual physical business address
- Phone number
- Email address
The physical address must be the real location of the business or individual. CBP has said it will not accept:
- a registered-agent address
- a customs broker or freight forwarder address
- a P.O. box
- a virtual office or business service center
- any address that belongs to another party
Phone and email must also belong to the importer, not to a broker, forwarder, or warehouse.
If a U.S. customs broker files Form 5106 for the importer, the broker must hold a valid power of attorney (POA) signed directly with that importer.
| 5106 field | Must belong to | Common mistake |
|---|---|---|
| Company name | Legal importer of record | Trade name / warehouse name |
| EIN / tax ID | The same legal entity | Old EIN after a merger |
| Physical address | Actual place of business | Agent, forwarder, P.O. box, virtual office |
| Phone & email | Importer’s own contacts | Broker mailbox that nobody monitors |
| Broker POA | Signed directly by the importer | POA passed through a forwarder |
Who is most exposed
Risk is highest for companies that have not updated 5106 data in years, or that never used their own identity in the first place:
- non-resident importers with no real U.S. office
- overseas sellers shipping DDP
- cross-border e-commerce using a third-party overseas warehouse as the “importer” address
- companies that registered with an old office, expired phone, or dead email
- long-standing importers that never refreshed 5106 after a move, merger, or name change
Freight forwarders and customs brokers can be pulled in as well. CBP has made clear that if a broker submits the data, both the importer and the broker are responsible for accuracy.
What happens if the IOR number is voided
A voided IOR number is invalid for any purpose, including making entry. That can stop:
- customs clearance
- port pickup
- trucking
- warehousing
- downstream delivery and inventory plans
CBP says it will send written notice to the most recent email address on file. If a broker last filed entry for that importer, CBP may copy the broker. The notice should explain why the number was voided and how to request reestablishment.
If that email is old or belongs to a third party, the company may not see the notice until freight is already stuck.
How to request reestablishment
CBP directs questions and reestablishment requests to IORProgram@cbp.dhs.gov, subject line: Enforcing IOR Accuracy.
Importers should be ready to prove identity: a corrected Form 5106, current tax/EIN evidence, and a POA no more than one year old if a broker signs the form. An officer of the company (president, VP, secretary, treasurer, CEO, COO, or equivalent) should sign where required.
Do not assume the old number will come back automatically. Plan for downtime until CBP accepts the new or corrected record.
What shippers and logistics teams should do this week
- Ask your U.S. customs broker to pull the IOR record now on file in ACE/ABI.
- Match it against the legal name, EIN, physical office, phone, and email you actually use.
- Replace any agent address, warehouse address, P.O. box, or virtual office.
- Confirm the broker’s POA is current and signed by the importer, not passed through a forwarder.
- Update Form 5106 before the next sailing if anything is stale.
- Make sure the email on file is monitored. That is where voiding notices go.
- For DDP and overseas-warehouse models, confirm who the real IOR is. If the named importer cannot support the 5106 data, change the structure before the next shipment.
Practical warning: A voided IOR is not a warning letter. It can freeze clearance immediately. Check the record before the next container arrives.
The larger point
For China exporters, U.S. importers, and logistics providers, compliance is no longer only about product, HS code, and country of origin. Importer identity is now an enforcement target.
A missing mailbox, a warehouse address used as a “U.S. office,” or a 5106 file that nobody has touched in five years can stop an entire supply chain.
This article is for general information only and is not legal advice. Confirm current CBP requirements with a licensed U.S. customs broker or trade counsel.
Sources
CBP, “Accuracy of Importer of Record Data Submitted to CBP,” Federal Register, Aug. 19, 2026 (91 FR 53627)
CBP Form 5106
CBP Voided Importer Record FAQs
Executive Order 14411, Strengthening Customs Enforcement
