On August 19, 2026, U.S. Customs and Border Protection (CBP) published a notice announcing enhanced enforcement of Importer of Record (IOR) registration data as part of the implementation of Executive Order 14411, Strengthening Customs Enforcement.
The CBP Form 5106 is the official CBP form used to establish or update an Importer of Record’s identity and registration information, including its legal name, tax ID, physical address, contact information, and other identifying details required to conduct import transactions with CBP.
Beginning September 18, 2026, CBP will actively validate information submitted on CBP Form 5106 (Create/Update Importer Identify Form). If CBP determines that inaccurate or incomplete information was provided on a CBP Form 5106, the consequences can be significant:
CBP will void the Importer of Record (IOR) number effective September 18, 2026, if it determines whether the information is inaccurate or incomplete. Once voided, the IOR number becomes invalid and cannot be used to enter merchandise into the United States.
CBP states it may take additional enforcement actions beyond voiding the IOR number, as appropriate.
CBP specifically calls out:
For companies importing into the U.S., the most immediate business risk is that a voided IOR number could interrupt import activity until the importer successfully reestablishes its IOR account with CBP. CBP will send notice to the email address on file and provide instructions for requesting reinstatement.
Requests for reestablishment of a voided IOR number may be submitted via email to [email protected] using the subject line “Enforcing IOR Accuracy.”
Please reach out to your C.H. Robinson representative with any questions.
Federal Register: Accuracy of Importer of Record Data Submitted to CBP
Federal Register: Strengthening Customs Enforcement
Importer Create/Update Identity Form (CBP Form 5106) FAQ | U.S. Customs and Border Protection
CBP Form 5106 - Create/Update Importer Identity Form | U.S. Customs and Border Protection