Why is CBP voiding importer of record numbers? (Form 5106 accuracy, from September 18, 2026)

The Form 5106 is the record CBP keeps of who an importer is. The notice requires every element on it to be accurate, complete, and to belong directly to the importer of record: the physical address, the email address, the phone number, and the IRS employer identification number (or Social Security number) the record is keyed to.

Two of those carry specific rules. The physical address cannot be a registered agent, a customs broker, a freight forwarder, a P.O. box, a business service center, or the address of another person or entity — though the principal's home address is allowed. The email address and phone number have to be the importer's own; a broker or other third party may not put its own contact details in their place. And a customs broker submitting the form for a client needs a power of attorney executed directly with that importer.

From September 18, 2026, if CBP finds that the information on file is inaccurate or incomplete, it voids the IOR number immediately. CBP sends a written notice of that action to the email address the importer most recently submitted, stating the basis for the decision. A voided number cannot be used to make entry, so goods arriving under it stop at the border.

The notice describes one route back: a request to reestablish the number, sent by email to CBP's IOR Program with the subject line "Enforcing IOR Accuracy." It gives no timeline for a decision on such a request.

The voiding notice goes to the email address on the Form 5106. If a broker set the record up years ago with its own address — exactly what the notice now prohibits — the importer never sees the notice and learns of the voided number when a shipment cannot be entered. That is the practical reason the email rule matters more than it looks.

The form is filed and updated by the importer of record, or by a customs broker holding a power of attorney executed directly with that importer. Filing it for someone else is customs business, so the correction itself sits with the broker or with the importer's own submission.

What an importer can do today is simple: ask the broker who set up the importer number to pull the Form 5106 on file and read every element back — address, email, phone, EIN — and check each one against the rules above. If anything is a broker's or forwarder's detail rather than the importer's own, that is the item to have corrected before September 18.

For most companies the IRS employer identification number doubles as the importer of record number, and every entry is filed against it — the bond, the duties owed, and any notice CBP sends all attach to that record. That is why the executive order names correctly identified, accountable importers of record as one of its goals, and why a stale Form 5106 can now stop a shipment that is otherwise in order.