Is Your CF 5106 Up-To-Date?

Sep 3, 2026 | Trade Compliance

On June 3, 2026, President Trump signed Executive Order 14411 (Strengthening Customs Enforcement). This Executive Order brought focus to possible weak points and loopholes in the US Customs framework and directed the Secretary of Homeland Security to review current practices and laws to ensure proper import enforcement is being accomplished.

To begin the process, US Customs issued a notice in the Federal Register on August 19, 2026. This noticed, named “Accuracy of Importer or Record Data Submitted to CBP” is an initial step by CBP to comply with the requirements and timeframe laid out in Executive order 14411. In this notice, CBP announces they will be “executing enhanced enforcement procedures to verify the accuracy of the information provided by new and existing importers of record on the CBP Form 5106”.

Customs Form 5106 (Create/Updates Importer Identity Form) is the form US Customs utilizes to create an importer of record identity. Information contained on this form provides US Customs with detailed information such as name and contact details of an entity, be it an individual or a company, who will be acting as the legal recipient of imported merchandise into the United States.

On September 18, 2026, CBP will begin the process of voiding Importer of Record (IOR) numbers for which inaccurate or incomplete information is contained on Form 5106. A voided IOR number can no longer be used to enter merchandise into the United States. CBP will notify importers through a written notice directly to the email address most recently submitted to Customs. Customs may also copy the importer’s customs broker that last filed an entry on behalf of the IOR. Further enforcement action may be taken by CBP or other Government Agencies under

  • The False Claims Act
  • 19 U.S.C Part 1641 (Customs Brokers)
  • 18 U.S.C Part 1001 (False Statements)
Importers responsibilities to avoid their IOR number(s) being voided
  1. Review your Form 5106 information on file.
  2. Verify the address listed on the 5106 is a physical address of the importer
    1. This address cannot be a P.O. Box, customs broker, freight forwarder or third-party service provider
  3. Make sure email address on file is a valid email of the importer
    1. Email addresses cannot be a customs broker or any other third party or other unrelated party
  4. Review current phone number listed. Must be a phone number of the importer
    1. Phone number cannot be a customs broker, freight forwarder or any other third-party service provider
  5. Customs brokers submitting form 5106 on behalf of an importer must have a valid Power of Attorney on file. The POA must be directly between the broker and the importer and not through a third party

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