Friday is the date. On September 18, CBP begins voiding importer of record numbers when the data on file is wrong.
There is no warning letter first. The Federal Register notice says a voided number is "invalid for any purpose, including entering imported merchandise into the United States." Your container reaches the port and cannot be entered. Nobody calls you first.
The notice ran on August 19, 2026 at 91 FR 53627. (general notice, FR Doc. 2026-16911) The trade press picked it back up last week as the date got close. (Supply Chain Dive, September 11, 2026) You have four days.
What CBP is checking
CBP Form 5106 is the Create/Update Importer Identity Form. It is how you or your broker got your importer number. It carries your importer name, EIN or SSN, mailing address, physical location address when that differs from the mailing address, phone number, and email address.
CBP says it is "comprehensively reviewing the CBP Form 5106 information on file for IORs for accuracy." Starting Friday, a record it judges incomplete or inaccurate gets the number voided, with other enforcement possible on top.
This traces back to Executive Order 14411, Strengthening Customs Enforcement, signed June 3, 2026 and published at 91 FR 35125. Section 2(e) directs DHS to confirm active importers are compliant. The Form 5106 sweep is the first visible piece.
The address rule will catch DTC brands
CBP singles out the physical address, and the language is blunt:
It cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center, or an address of another person or entity.
Read that last clause twice. The notice does not name third-party warehouses, but a building your fulfillment partner owns and operates is an address of another entity. Plenty of brands put a warehouse or broker address on the form years ago because it was the only one that felt like a real business location.
CBP answers that in a footnote: the address associated with the business can be the principal's home address. So the fix for most small brands is their own address, even if it is a spare bedroom in Grandview. Use a warehouse address for freight routing, not for identity.
The email field is the trap underneath the trap
CBP requires that the email address on the form belong to the importer. A broker or forwarder cannot substitute its own.
Now look at what happens when a number gets voided. CBP sends written notice "to the email address the IOR most recently submitted to CBP." That notice carries the reason and the reinstatement instructions.
If your broker's email is sitting in that field, two things happen at once. The wrong email is part of what makes the record inaccurate. And the only notice you will receive goes to an inbox you do not read. Brands in that position find out at the port.
CBP does copy the broker who last filed entry for you. Whether that broker forwards it the same day is a question about your relationship, not about customs.
Four things to verify before Friday
- Physical address. Your actual location. Not a warehouse, not a broker, not a forwarder, not a mailbox service.
- Email and phone. Both must belong to you and both must work. Pick an inbox a human checks daily, not a
no-replyalias. - EIN or SSN. Accurate and complete, and matching what the IRS has for the legal entity that owns the goods.
- Power of attorney. If a broker files for you, the POA must be executed directly with you. A POA that runs through a freight forwarder does not satisfy 19 CFR 111.36(c)(3).
Questions about a voided number go to IORProgram@cbp.dhs.gov with the subject line "Enforcing IOR Accuracy." CBP has not published a turnaround time for reinstatement, which is the part that should worry you in mid September.
Talk to your customs broker or trade counsel about the filing itself. That is their job, not ours.
What this means for your brand
Sort out who the importer of record actually is before Friday, and write it down somewhere your team can find it. A brand moving 1,000 to 25,000 orders a month has a supplier, a forwarder, a broker, and a fulfillment partner touching the same shipment. Each one assumes somebody else keeps the customs record current. That assumption is what gets numbers voided.
The identity data belongs to you. Freight and parcels are where a fulfillment partner earns its keep. We covered the other half of this shift when CBP set September 22 for electronic mail entries. Both notices point the same direction. The informal lane is closing, and the paperwork behind every import is getting checked against a real company.
Our international shipping runs through FlavorCloud, DHL, UPS, and USPS, with DDP available so duties get collected upfront. Inbound containers get received and counted in Canal Winchester, and outbound orders leave within 24 hours. None of that helps if your importer number stops working Friday, which is why this one is worth an hour today.
Not sure whose address is on your 5106? Send us your last few inbound shipments and we will show you which entity the paperwork names.
FAQ
Can my 3PL be the importer of record?
Sometimes, and it is a real decision rather than a default. A fulfillment provider acting as importer of record takes on liability for duties and for the accuracy of the entry. Most 3PLs, including us, do not want that role for a client's inventory. What matters Friday is that whoever holds the role has their own contact data on Form 5106.
I only import a few sample shipments a year. Does this apply to me?
Yes. The notice covers new and existing importers of record with no volume floor. Low-frequency importers are arguably more exposed. A record set up once in 2021 and never touched again is exactly what this review is built to find.