CBP Form 5106 and IOR Enforcement What Importers Need to Know Before September 18 2026 Q and A
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- 6 days ago
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A wrong address, outdated phone number, mismatched EIN, or indirect Power of Attorney may soon do more than slow down an import entry. It could cause U.S. Customs and Border Protection to void an Importer of Record number, stopping merchandise from entering the United States until the problem is fixed.
Based on Executive Order 14411, Strengthening Customs Enforcement, and CBP’s subsequent Federal Register notice on Importer of Record data accuracy, CBP is moving toward stronger verification of importer identity, eligibility, and compliance status. The key date is September 18, 2026. Beginning on that date, CBP may immediately void an IOR number if information provided on CBP Form 5106 is inaccurate, incomplete, or cannot be verified.
For importers, foreign sellers, e-commerce companies, freight forwarders, and customs brokers, this is not a small recordkeeping update. It changes how importer data, Powers of Attorney, and foreign Importer of Record arrangements must be reviewed before goods move.
This article is for general informational purposes only and should not be treated as legal advice.
CBP is increasing scrutiny of Importer of Record data
CBP Form 5106 is used to create or update an Importer of Record account with CBP. The information on that form helps CBP identify who is legally responsible for imported merchandise, duties, taxes, fees, records, and compliance obligations.
Under the enhanced enforcement approach described by CBP, the Importer of Record must be real, eligible, identifiable, and reachable. CBP is no longer treating weak or unverifiable IOR data as a paperwork issue that can always be corrected later.
Starting September 18, 2026, CBP may immediately void an IOR number if the CBP Form 5106 data is found to be:
Inaccurate
Incomplete
Unverifiable
A voided IOR number cannot be used to enter merchandise into the United States until the issue is resolved. That means cargo may face entry rejection, release delays, storage charges, demurrage, missed delivery obligations, or enforcement review.
The practical message is clear. Importer records should be checked before shipment, not after cargo arrives.
What must be accurate on CBP Form 5106
CBP has emphasized that all information submitted on CBP Form 5106 must belong directly to the Importer of Record. It is not enough for the information to be convenient, commonly used, or supplied by a logistics partner.
The importer’s record should reflect the actual company or individual acting as Importer of Record.
Key data points include:
CBP Form 5106 information | What CBP expects |
Business name | The legal name of the Importer of Record |
EIN or tax identification information | The correct identifier belonging to the importer |
Physical address | The importer’s actual business location |
Email address | A valid email connected to the importer |
Telephone number | A working number connected to the importer |
Responsible party information | Accurate information for the party responsible for import obligations |
The physical address requirement deserves special attention. CBP has stated that the physical address must be the importer’s actual business location. It cannot be the address of a freight forwarder, customs broker, registered agent, business service center, mail receiving agency, or other third party.
This point may affect many importers that have historically used a third-party address for convenience. If the listed address does not reflect the importer’s actual business location, the IOR record may be questioned.
Power of Attorney rules are becoming more direct
Customs brokers must have a valid Power of Attorney before transacting customs business on behalf of an Importer of Record. CBP has made clear that the POA must be executed directly with the Importer of Record.
That means a customs broker may not rely on a POA obtained through a freight forwarder or another intermediary.
This is a major compliance point. In many shipping arrangements, logistics communication flows through a forwarder, supplier, platform, or third-party coordinator. CBP’s position places responsibility back on the direct legal relationship between the customs broker and the Importer of Record.
A valid POA process should confirm:
That the importer exists and can be identified
That the person signing has authority to bind the importer
That the POA is signed directly by the Importer of Record
That the broker is not relying only on documents passed through an intermediary
That supporting records are retained
For importers, this may mean additional onboarding steps before entries are filed. For brokers, it means stronger documentation before accepting instructions. For freight forwarders and sellers, it means the importer relationship cannot be treated as a behind-the-scenes formality.
Foreign Importers of Record will face closer review
CBP has also advised CTPAT-validated customs brokers that Executive Order 14411 will require a substantially higher level of due diligence when representing foreign Importers of Record.
This is especially important for overseas exporters that currently act as the Importer of Record for U.S. shipments. CBP guidance points to heightened scrutiny of foreign IOR arrangements and a stronger preference for accountable U.S.-based Importers of Record.
That does not mean every foreign IOR arrangement will automatically be prohibited. It does mean CBP and customs brokers are expected to ask more questions and keep better records.
Due diligence for foreign importers may include verification of:
Legal identity
Ownership structure
Business affiliations
U.S. assets
Compliance history
Import activity
Ability to satisfy customs obligations
Authority of the POA signer
Supporting company records
CBP expects brokers to maintain records supporting their vetting efforts and POA validation. That shifts the process from basic data collection to a more complete importer review.
For foreign sellers, the key question is no longer only, “Can we be listed as the Importer of Record?” The better question is, “Can our identity, authority, records, and compliance responsibility be verified to CBP’s expectations?”
Why importers should review records before goods ship
A voided IOR number is not just an administrative inconvenience. If the number cannot be used, the entry process may stop until the importer record is corrected and accepted.
That can create problems across the shipment timeline.
Cargo may arrive before the importer issue is resolved. A port, rail terminal, airline warehouse, container freight station, or final delivery schedule may be affected. If the goods are time-sensitive, the commercial impact can grow quickly.
Common risk areas include:
Old CBP Form 5106 records that were never updated
Business names that changed after a merger, acquisition, or reorganization
EIN records that do not match the listed legal entity
Third-party addresses used as the importer’s physical address
Phone numbers or email addresses that no longer work
POAs signed by a party that is not clearly authorized
Foreign sellers acting as IOR without verifiable U.S. compliance support
Importer accounts opened long ago with incomplete supporting records
The safest time to identify these issues is before booking cargo, not after arrival.
I-Logix Customs has enhanced its POA and CBP Form 5106 validation process
I-Logix Customs’ enhanced POA and CBP Form 5106 validation process is already live and in effect.
Before processing customs entries, I-Logix Customs must verify the importer’s identity and supporting documentation to help meet CBP’s current and upcoming enforcement requirements. This applies to both new and existing importer accounts.
The review may include confirmation of company identity, importer contact details, physical address, POA authority, and supporting documentation. For foreign importers, additional due diligence may be needed based on CBP’s expectations for CTPAT-validated customs brokers.
This process is designed to reduce the risk of shipment delays, entry rejections, and compliance issues after September 18, 2026.
I-Logix Customs Inc. is a CTPAT-certified customs broker and can assist with customs entries, POA review, CBP Form 5106 validation, and shipment scenario review. If there are specific shipment structures, foreign IOR questions, or importer setup concerns, I-Logix Customs can review them before cargo moves.
What importers should do now
Importers should use the period before September 18, 2026, to clean up records and confirm that all parties understand who is legally acting as the Importer of Record.
A practical review should include these steps.
Confirm the correct Importer of Record
Make sure the company listed as IOR is the correct legal party responsible for the import. If an overseas exporter, U.S. buyer, related company, or marketplace entity is involved, confirm who should legally appear as the importer.
Review CBP Form 5106 data
Check the importer’s legal name, EIN, physical address, email address, phone number, and responsible party information. Make sure the data belongs directly to the importer and can be verified.
Replace third-party physical addresses
If the importer’s physical address is currently a broker, forwarder, registered agent, mail center, or business service center address, review it. CBP expects the actual business location of the importer.
Validate the POA
Confirm that the POA was executed directly between the customs broker and the Importer of Record. The signer should have authority to bind the importer.
Review foreign IOR arrangements
If an overseas exporter or non-U.S. entity acts as the Importer of Record, review whether that structure can support CBP’s enhanced due diligence expectations.
Keep supporting records
Maintain documents that support the importer’s identity, business location, ownership or signing authority, and ability to meet customs obligations. Brokers must also keep due diligence and POA validation records.
Q and A
What happens if CBP voids an IOR number?
A voided IOR number cannot be used to enter merchandise into the United States until the issue is resolved. This may delay release and require corrected or verified importer information before the shipment can proceed.
When does the new enforcement date begin?
CBP may begin immediately voiding IOR numbers for inaccurate, incomplete, or unverifiable CBP Form 5106 information on September 18, 2026.
Can an importer use a freight forwarder’s address on CBP Form 5106?
CBP has stated that the physical address must be the importer’s actual business location. It cannot be the address of a freight forwarder, customs broker, registered agent, business service center, or other third party.
Can a customs broker rely on a POA provided through a freight forwarder?
CBP has emphasized that customs brokers must execute a valid POA directly with the Importer of Record. A broker may not rely on a POA obtained through a freight forwarder or another intermediary.
Can an overseas exporter still act as the Importer of Record?
Foreign IOR arrangements may still exist, but they will face greater scrutiny. CBP guidance indicates a stronger preference for accountable U.S.-based Importers of Record and expects more due diligence when brokers represent foreign importers.
Does this apply to existing importer accounts?
Yes. I-Logix Customs’ enhanced validation process applies to both new and existing importer accounts. Existing records should be reviewed before future shipments.
What should importers review before shipping?
Importers should review their POA, CBP Form 5106 information, company records, physical address, contact information, and importer structure. The goal is to make sure the IOR data is accurate, current, and verifiable before cargo moves.
The September 18, 2026 deadline gives importers time to prepare, but waiting until cargo is in transit creates unnecessary risk. Accurate importer data, a direct POA, and clear supporting records are now central parts of customs readiness. For any uncertain shipment scenario, review the importer structure before booking and confirm that the IOR can stand up to CBP verification.
If you have more questions, please feel free to email us at Compliance@Ilogixchb.com .
Published by Erica Dean | I-Logix Customs INC
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