In a Federal Register notice scheduled to be published August 19, 2026, Customs and Border Protection (CBP) will be announcing that it will begin implementing enhanced enforcement procedures to verify the accuracy of the importer of record information from form 5106. These new procedures are in response to Executive Order 14411 “Strengthening Customs Enforcement” and are scheduled to go into effect 30 days after CBP publishes this change in the Federal Register (September 18, 2026, provided the notice is published as scheduled).

IOR Required Information

Anyone importing goods into the U.S. must register as an importer of record using CBP Form 5106, providing accurate information including:

• Importer name
• Tax ID (EIN, SSN, or CBP-assigned number)
• Mailing address
• Physical location address
• Phone number
• Email address

 What's Changing

Starting 30 days (projected to be September 18, 2026) after this notice is published in the Federal Register, CBP will begin immediately voiding IOR numbers if it finds the information on file is inaccurate or incomplete. This means the importer can't legally bring goods into the U.S. until the number is reinstated.

Information CBP Will Be Emphasizing

• The physical address must be the importer's real location — not a customs broker's office, freight forwarder, registered agent, or P.O. box (a home address is acceptable for individuals).
• The email and phone number must actually belong to the importer — brokers or third parties can't substitute their own contact info.
• Customs brokers filing on behalf of importers must have a valid, direct Power of Attorney with that importer (not routed through a freight forwarder).

Consequences If CBP Finds the IOR Information is Incorrect

Importers who provided false or incorrect information on form 5106 face potential criminal penalties under 18 U.S.C. § 1001 for knowingly false statements and potential liability under the False Claims Act, since inaccurate IOR data ties to duty payment obligations. Brokers who submit false or inaccurate data risk penalties under 19 U.S.C. § 1641.

Process for Reinstatement of IOR

After determining that inaccurate information was provided on form 5106 and voiding the IOR, CBP will email a notice explaining why the IOR number was voided (copying the broker if applicable) and how to request reinstatement by verifying identity.

For further information about this and other Customs matters, contact George Tuttle III at geo@tuttlelaw.com or 415-986-8780.

The information in this article is general in nature and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence and may not be considered as such.

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