Since September 18, 2026, U.S. Customs and Border Protection (CBP) has been voiding importer of record numbers when the information behind them is inaccurate or incomplete. There is no warning period and no cure period. Once a number is voided, it cannot be used for any purpose, including entering goods into the United States. An importer of record number is the identifier CBP issues based on the details an importer registers on CBP Form 5106, and every entry is filed under one.
Quick look
- The legal basis is Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026. CBP announced the enforcement in the Federal Register on August 19, 2026.
- CBP is reviewing Form 5106 data for new and existing importers. Inaccurate or incomplete information can lead to the number being voided immediately.
- The physical address, email, and phone number must belong to the importer. A customs broker, freight forwarder, registered agent, or P.O. box address does not qualify.
- If you buy on DDP terms, the importer of record is usually your supplier. If their number is voided, it is your shipment that stops.
What Changed on September 18
On June 3, 2026, the President signed Executive Order 14411. Among other things, it directs the Department of Homeland Security to confirm that active importers of record comply with all applicable regulations and disclosures. CBP's first step came in a general notice published in the Federal Register on August 19, 2026 (91 FR 53627).
The notice says CBP is comprehensively reviewing the Form 5106 information on file for importers of record. Beginning September 18, if CBP determines that an importer, or a broker acting for one, failed to provide complete and accurate information, it will void the number. CBP may also take other enforcement action.
Notice of a voided number goes to the email address the importer most recently gave CBP, with a copy to the broker that last filed an entry for that importer. The notice explains why the number was voided and how to request that it be reestablished. As of a September 21 FreightWaves report, CBP had not said publicly how many numbers it has voided.
One point to keep separate: CBP has also deactivated a large number of importer numbers for inactivity. That is a different action from this accuracy review.
Importer of Record Number Requirements: Four Details on Form 5106
Form 5106 asks for the importer's name, tax ID (an IRS employer identification number, Social Security number, or CBP-assigned number), mailing address, physical address if different, phone number, and email address. The notice spells out what CBP expects for four of these details.
- Physical address. It must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center, or the address of another person or company. A principal's home address can qualify.
- Email address. It must be valid and belong to the importer. A broker or other third party may not substitute its own email address.
- Phone number. The same rule applies. The number must belong to the importer, not to the broker or anyone else.
- Power of attorney. A broker filing for an importer must hold a valid power of attorney executed directly with that importer, not through a freight forwarder or other third party.
The notice also reminds importers that knowingly false statements on the form can carry criminal liability under 18 U.S.C. 1001 and civil liability under the False Claims Act.
Why Now: Shell Companies and Borrowed Identities
The Federal Register notice itself does not mention shell companies. That context came from CBP's Trade and Cargo Security Summit in Dallas on September 8–10. According to a summary published by the law firm Diaz Trade Law, CBP described increasingly sophisticated fraud involving stolen identities, shell companies, fraudulent powers of attorney, and importers of record that do not exist.
The same summary reports that CBP said its focus is not on ordinary clerical mistakes, but on parties intentionally exploiting the system. Even so, the notice gives CBP authority to void a number for inaccurate or incomplete information, so it makes sense to treat every field as something that will be checked.
Why Buyers Should Care: On DDP Terms, the Importer Is Your Supplier
Many US buyers never deal with Form 5106, because they never act as the importer. Under DDP (Delivered Duty Paid) terms, the seller handles import clearance, and the importer of record is usually the overseas supplier or someone the supplier appoints.
That is where the new enforcement reaches buyers. A foreign company with no office in the US has no US physical address to register. A common workaround has been to list a broker's or agent's address, which is exactly what the notice says is not acceptable. FreightWaves reported that the importers most exposed include nonresident importers, foreign sellers acting as importer of record on DDP shipments, e-commerce sellers using third-party fulfillment centers, and smaller importers whose records have not been updated in years.
If your supplier's number is voided, the goods waiting at the port are yours. And because CBP sends the notice to the importer, not to you, you may be the last to find out.
None of this means DDP terms are a problem in themselves. It means the importer of record on your shipments is now worth asking about.
Three Questions to Ask Before Your Next Shipment
- Who is the importer of record? Is it a company with a real US physical address, or one registered under an agent's address?
- Is the power of attorney signed directly? Ask whether the importer executed it directly with the customs broker that files the entries.
- Who handles it if the number is voided? Check whether your contract says who resolves a hold at the port and who pays for storage and delays.
On shipments we purchase, our U.S. company is the importer of record. You can read how that works in Importer of Record, On the Ground in Asia: Our Two Companies.
Importer of record number: common questions
Can a voided importer of record number be restored?
Yes, you can request that it be reestablished. CBP's notice of voiding explains how, including what information you need to submit to confirm the importer's identity.
My customs broker registered me using the broker's own email. Is that a problem?
Under the notice, the email address and phone number must belong to the importer. A broker or third party may not supply its own in place of yours.
We have no office in the US. Can we use our broker's address?
Not under the notice. The physical address must be your actual location. A broker, forwarder, or registered agent address does not qualify.
Will a simple typo get a number voided?
The notice says inaccurate or incomplete information can lead to voiding. CBP has said its focus is intentional abuse, but it is safer to keep every detail current and correct.
If you buy from Asia and want to see how we source and import the goods we purchase, get in touch with our team.
Further reading
- Continuous Bond vs. Single Entry Bond: Which Do You Need?
- ISF Filing and Bond Claims: What Your Customs Bond Misses
- Country of Origin: Substantial Transformation and Transshipment
This article is general information, not legal advice. Sources: Federal Register Vol. 91, p. 53627 (August 19, 2026), "Accuracy of Importer of Record Data Submitted to CBP"; Executive Order 14411 (91 FR 35125); FreightWaves, September 21, 2026; Diaz Trade Law summary of the 2026 CBP Trade and Cargo Security Summit, September 18, 2026. Checked October 13, 2026.