CBP Importer of Record Accuracy Rules Take Effect September 18: What Every Importer Must Fix Now?

U.S. Customs and Border Protection (CBP) has begun a nationwide review of every Importer of Record (IOR) file on record, and the deadline to fix errors is closing fast. Under a notice published August 19, 2026, CBP will start voiding IOR numbers with inaccurate or incomplete data on September 18, 2026. For importers who rely on ocean or air freight from Vietnam and other origins, that leaves less than a month to confirm that CBP Form 5106 is correct, or risk having shipments stopped at the border.

At Worldcraft Logistics, we work daily with importers moving cargo through our Ontario, Cerritos, and Union City warehouses, and this is one of the most consequential compliance changes we have seen this year. Below is what the rule actually requires, who is affected, and the exact steps to take before the deadline.

What Is CBP Form 5106 and Why Does It Matter

CBP Form 5106, officially the Create/Update Importer Identity Form, is the document every importer must file to receive an IOR number. The IOR number is what allows a company or individual to legally bring merchandise into the United States, request a customs bond, or receive a duty refund. Without a valid IOR number, a shipment cannot clear customs, no matter how correct the rest of the entry paperwork is.

Regulatory changes like this rarely come alone. If you are already reviewing your import compliance for the CBP Form 5106 deadline, it is worth checking these related updates as well:

• New CPSC eFiling Rule Starts July 8, 2026: Are You Ready?
• US Import & Export Price Indexes Update 2026

What Changed Under the New CBP Notice

The notice implements Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026. It directs the Department of Homeland Security to confirm that active importers are compliant with all applicable regulations and disclosures. CBP's response is a full file-by-file review of every Form 5106 on record, followed by immediate action against any importer whose information does not check out.

1. Effective Date

The enhanced enforcement, including the immediate voiding of noncompliant IOR numbers, begins September 18, 2026.

2. What Happens If Data Is Wrong

Starting on that date, if CBP determines that an IOR's information is inaccurate or incomplete, it will void the IOR number immediately. A voided IOR number cannot be used for any purpose, including entering merchandise into the United States, which in practice means shipments stop moving until the number is reestablished.

The Five Data Points CBP Is Reviewing

CBP is focused on five specific elements of Form 5106. Each one must belong directly to the importer, not to a broker, freight forwarder, or third party service.

1. Physical Address

This must be the importer's actual business or personal location. A registered agent address, customs broker address, freight forwarder address, P.O. box, or business service center address does not qualify.

2. Email Address

The email on file must be valid and must belong to the importer. A broker or third party cannot substitute their own email in place of the importer's.

3. Phone Number

The same rule applies to the phone number. It must be a working number that belongs to the importer, not the broker or another intermediary.

4. EIN or SSN

The IRS Employer Identification Number or Social Security Number on file must be accurate and complete.

5. Power of Attorney

If a customs broker files Form 5106 on an importer's behalf, that broker must hold a valid Power of Attorney executed directly with the importer. A POA obtained through a freight forwarder or other third party does not satisfy this requirement.

Who Is At Risk

This applies to every active IOR, whether a large importer with an in house trade compliance team or a small business that only ships a few containers a year. Companies that historically used a broker's office address or a forwarder's contact details as a placeholder on Form 5106 are the most exposed, since that is precisely the pattern CBP is targeting.

What Happens If You Do Not Fix It

The financial and legal exposure goes beyond a paused shipment. The certifying party who submits Form 5106 can face the following.

1. Fines or Imprisonment

Under 18 U.S.C. Section 1001 for knowingly making a false statement to a federal agency.

2. False Claims Act Liability

Under 31 U.S.C. Section 3729 and related sections, because IOR data is considered material to the importer's obligation to pay duties.

3. Broker Penalties

Under 19 U.S.C. Section 1641 for submitting inaccurate or invalid information on a client's behalf.

How to Prepare Before September 18

1. Pull Your Current Form 5106 Record

Confirm the physical address, email, phone number, and EIN or SSN on file with CBP are current and belong to your company directly, not to a broker, forwarder, or service address.

2. Verify Your Power of Attorney

Confirm your customs broker holds a POA executed directly with your company, not through a freight forwarder or other intermediary.

3. Correct Discrepancies Now, Not Later

CBP has signaled there will be no extended grace period once enforcement starts on September 18.

4. Loop In Your Logistics Partner

If Worldcraft Logistics manages your freight, ask your account manager to confirm which contact details are on file with your broker of record so there is no mismatch between your shipping documents and your CBP profile.

Talk to Worldcraft Logistics Before the Deadline

Shipments already in transit or scheduled for late September could be delayed if an IOR number is voided mid-route. Contact Worldcraft Logistics today to review your import documentation and make sure your Form 5106 details, broker POA, and shipping records are aligned before the September 18 enforcement date.