CBP is currently conducting a comprehensive review of the Importer of Record information submitted and maintained on CBP Form 5106 and, beginning September 18, 2026, will void an IOR number if it determines that the information on file is inaccurate or incomplete.

A voided IOR number will no longer be valid for importing merchandise, and CBP may also take additional enforcement action, as appropriate.

Importers, or customs brokers providing information on an importer’s behalf, must ensure that all information on file, including physical addresses, email addresses, phone numbers, Internal Revenue Service (IRS) employer identification numbers (EINs), and any Social Security numbers (SSNs), is accurate, complete, up to date, and belongs directly to the IOR. Brokers must also have a valid Power of Attorney executed directly with the IOR.

Please review your Form 5106 information now.

For further information, please contact us.

• increasing bonding requirements and requiring IORs to maintain a minimum level of tangible domestic assets, bonding, or both;
• subjecting foreign IORs to heightened requirements for formal entry;
• limiting informal entry filings to U.S.-based IORs;
• imposing a “good standing” requirement on all IORs and their affiliates; and
• increasing vetting procedures for all individuals and entities engaged in activities directly related to the importation of goods, including foreign IORs, affiliates of IORs, customs brokers, custodians of bonded merchandise, and freight forwarders.

In addition, the order directs DHS and CBP to establish enhanced import disclosure and certification requirements and to increase customs enforcement. Among other measures, the order calls for the establishment of a minimum penalty “floor” of 50%, limiting CBP’s discretion to mitigate penalties, and directs DHS to expedite and enhance the seizure and disposal of non-compliant imports

The executive order signals a significant shift toward enhanced customs enforcement and stricter importer accountability.

Accordingly, we encourage you to take this opportunity to ensure that your company is complying with all applicable import regulations, including classification, valuation, origin disclosures, marking, etc.

Now may be the ideal time to conduct an internal audit to assess your compliance.

We are at your disposal to prepare an audit plan, review your classifications, and reconfirm your valuation methodology. To discuss the best next steps for your company, please contact us.