Customs
CBP Is Voiding Importer Numbers. Is Your Form 5106 Right?
Quick answer: A voided importer of record number cannot be used to enter merchandise, so shipments stop at the border until it is reestablished. Since 18 September 2026, CBP voids one immediately where the Form 5106 data is inaccurate or incomplete, and it is reviewing every importer number on file regardless of age. The detail that catches most overseas sellers is the physical address: it cannot be your customs broker, your freight forwarder, a registered agent, a PO box or a business service centre. Phone and email have to be yours too. Most sellers have never seen their own form, because a broker filled it in years ago.
There is a single line on a form you have probably never read that can stop every shipment you have in transit.
It is not new law, and there is no grace period left to use. The enforcement is live, it applies to importer numbers opened decades ago as readily as ones opened last month, and the first most sellers hear of it is a container that will not clear.
CBP published a notice in the Federal Register on 19 August 2026. Since 18 September 2026, where the information on an importer's Form 5106 is inaccurate or incomplete, CBP immediately voids the associated importer of record number.
A voided number is invalid for any purpose, including entering merchandise into the United States. It is not a warning or a fine. The number simply stops working.
The notice forms part of the initial implementation of Executive Order 14411, Strengthening Customs Enforcement. CBP has said it is reviewing the data behind every importer number on file, whether the account was opened last month or twenty years ago.
That last point matters more than the date does. This is not a rule that applies to new registrations. It is a review of everything already in the system.
If the name is unfamiliar, the number it produces will not be.
Form 5106 is the Create/Update Importer Identity Form. It establishes or updates your identity in CBP's systems under 19 CFR 24.5 and produces the importer of record number that appears on every entry you make. For a US company that is usually tied to an IRS EIN. For an individual it may be a Social Security number. For a foreign importer with neither, CBP assigns a number.
Most sellers have never seen their own form. It was filled in once, often by a customs broker or forwarder during onboarding, and never looked at again. That is precisely the problem this rule creates.
CBP's notice identifies the data that must be accurate, complete and directly associated with the importer:
Four of those are usually fine. The fifth is where this bites.
CBP has been specific about what a physical address cannot be:
| Not acceptable as your physical address |
|---|
| A registered agent's address |
| A customs broker's address |
| A freight forwarder's address |
| A PO box |
| A business service centre |
| An address belonging to another person or entity |
It has to be the importer's actual place of business, or an associated residential address.
Read that list again if you are selling into the US from outside it, because at least one of those is probably what is on your form right now. When a broker or forwarder sets up an importer number for an overseas client, using their own address is the path of least resistance. It has been normal practice for years. It is now a voidable defect.
The same logic applies to contact details. Your phone number and email must be yours, not your broker's, not your forwarder's, not a shared operations mailbox at a service provider.
Here is the part that turns an administrative problem into an expensive one.
CBP says it will issue written notice to the importer's last provided email address, explaining why the number was voided and how to seek reestablishment.
If the email on your Form 5106 belongs to a forwarder you stopped using in 2023, that is where the notice goes. You will not see it. The first you will know is a shipment that will not clear, and then you will be trying to work out why while the clock runs.
An inaccurate email is both the defect that gets you voided and the reason you do not find out.
None of this is difficult. It is just easy to leave undone until it is urgent.
Find out what CBP actually holds for you. Not what you think you submitted. Your customs broker can tell you what is on file against your importer number. Ask them directly and ask for the specific fields, not a reassurance.
Check the physical address against the list above. If it is a broker, forwarder, registered agent, PO box or service centre, it needs to change.
Check the email and phone. If a notice were sent today, would it reach someone at your company who would act on it?
Correct it properly. A Form 5106 update is submitted to CBP and takes around five business days on average to process. That is not long, but it is longer than a container sits comfortably.
If you are a foreign importer, give the complete address. Province or state and postal code included. Incomplete is a defect in its own right.
Do not leave this until a shipment is in the air. The correction is routine; doing it under pressure is not.
We are a fulfilment provider in Shenzhen. We prepare and document shipments, and we hand them to carriers. We are not a licensed customs broker, we are not your importer of record, and we cannot file or correct your Form 5106.
One thing we should say plainly, because it is the whole point of this article: our address is not a valid physical address for your Form 5106 either. Neither is any warehouse, forwarder or agent address, ours included. If our details are on your form, that is a defect and it needs correcting.
For the correction itself, and for anything that has already become a problem with CBP, use a licensed customs broker or a trade attorney. That is their work, not ours.
What we can do is keep the documentation on our side accurate and consistent, which matters when your entries are being looked at more closely than they used to be. That is the substance of our tariff management service, and it sits alongside the broader question of how classification and valuation work.
Your importer of record number is the single point of failure in your US supply chain, and most sellers have never checked the record behind it.
A wrong address or an old email on a form somebody else filled in for you is now enough to switch it off. The fix takes an afternoon and about five business days to process. Finding out the hard way takes considerably longer, and it happens at the border rather than at your desk.
Ask your broker what CBP holds for you today. If our details appear anywhere on it, tell us and we will help you work out what should be there instead, then point you at someone licensed to change it.
Figures and requirements here are current as at 18 September 2026. Customs enforcement policy is moving quickly this year, so confirm the position before relying on it.
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See eCommerce Fulfillment →Form 5106 is the Create/Update Importer Identity Form. It establishes or updates an importer's identity in CBP's systems under 19 CFR 24.5 and assigns the importer of record number used to enter merchandise into the United States. That number is usually tied to an IRS EIN, a Social Security number, or a CBP-assigned number for foreign importers.
CBP published a notice in the Federal Register on 19 August 2026, and since 18 September 2026 it immediately voids an importer of record number where the Form 5106 information is inaccurate or incomplete. A voided number is invalid for any purpose, including entering merchandise. CBP has said it is reviewing the data behind every importer number on file, regardless of how long the account has existed.
Not as your physical address. CBP's notice states the physical address cannot be a registered agent address, a customs broker address, a freight forwarder address, a PO box, a business service centre, or an address belonging to another person or entity. It must be the importer's actual place of business or associated residential address. Phone number and email must also belong to the importer rather than a third party.
Yes. The enforcement applies to all importers of record entering merchandise into the US, including foreign entities, and to their associated customs brokers. Foreign addresses need to be complete, including province or state and postal code where those apply.
The number cannot be used to enter merchandise, which in practice means shipments stop until it is reestablished. CBP says it will issue written notice to the last email address provided, explaining the basis for voiding and giving instructions for seeking reestablishment. CBP has also indicated it may pursue further enforcement, and has referenced federal false statement statutes and False Claims Act liability.