US importer records: check your details before 18 September
CBP begins enhanced checks on Form 5106 importer information from 18 September 2026. Inaccurate records can lead to a voided importer number and prevent goods being entered into the United States.
- Who this affects
- UK sellers acting as the US importer of record, including under some DDP arrangements, and the brokers submitting their importer information.
- Seller action
- Check before sending affected goods
Confirm who is the importer. Check the name, importer number, actual business address and direct contact details on Form 5106 with your customs broker, and verify the broker’s direct power of attorney.
- Effective dates / current position
- Enhanced importer-record accuracy enforcement: — In forceTiming follows the confirmed published schedule; it is not a fresh legal review. The notice gives a date, not an exact commencement hour. US Eastern calendar time is used for display, not as a carrier cutoff. Existing importer-information obligations already apply. Date-only changes use the calendar day in America/New York.
- Last reviewed
- 17 Sept 2026 — an editorial source check, separate from automatic timing.
- Official source
- Open the primary source ↗
What changes on 18 September?
US Customs and Border Protection (CBP) begins enhanced enforcement of importer information recorded on Form 5106 from 18 September 2026. Its notice was published in the Federal Register on 19 August. It covers both new and existing importer records.
If CBP determines that information is incomplete or inaccurate, it will void the importer number immediately. That can prevent clearance using that number. The notice does not say that every importer number will be cancelled or every parcel delayed.

What is an importer of record?
The importer of record is the party responsible for the customs entry. Form 5106 is used to create or update its identity information with CBP; it is not a product approval or a customs description.
Start by asking your customs broker which legal entity and importer number your shipments use. Do not assume that selecting DDP tells you everything about the importer arrangement. This matters particularly where a UK seller is itself acting as the US importer.
What should you check?
- Identity: the importer’s name and its correct EIN, Social Security number or CBP-assigned number, as applicable.
- Physical address: the actual location of the business or individual. CBP says this cannot be a registered agent, broker, freight forwarder, PO box, business service centre or another entity’s address. The notice recognises that a business address can be the principal’s home.
- Email and telephone: valid details belonging to the importer, not a broker’s or unrelated third party’s substitute details.
- Broker authority: a valid power of attorney executed directly between the importer and the customs broker, not through a freight forwarder or another intermediary.
A practical example
A UK retailer uses its own importer number for US orders. Its broker originally supplied the broker’s contact details on the importer record. The retailer should ask the broker to review and correct the record using the importer’s genuine information. Changing the address printed on the next parcel alone does not update the underlying CBP record.
If a different business or customer is the importer, confirm that arrangement with the broker rather than submitting your own details in its place. Do not share sensitive identity documents through a public comment or social-media message; use the broker’s appropriate secure process.
What if a number is voided?
CBP will send its notice to the importer’s most recently recorded email address and may copy the broker that last filed an entry. The notice explains the reason and how to request re-establishment, including identity evidence.
Monitor that inbox and contact the broker promptly. Follow CBP’s re-establishment process; do not treat a replacement number as a workaround. The official notice gives IORProgram@cbp.dhs.gov for questions and requests, using the subject “Enforcing IOR Accuracy”.
What does this not change?
This notice concerns importer identity and enforcement. It does not itself introduce a new tariff, product approval or low-value duty exemption, or announce a blanket ban on foreign importers. Accurate descriptions, classification, origin and other applicable customs requirements remain separate checks.
Your next step: ask the broker to confirm the importer record and direct contact details before the next shipment. Keep a record of corrections and who is monitoring CBP correspondence.
Official source
Related: the pre-dispatch checklist and US origin and classification guidance.