Importers Must Confirm Accuracy of Importer of Record Information With CBP
On August 19, 2026, U.S. Customs and Border Protection (CBP) published a General Notice announcing the agency intends to take action against importers (or their customs brokers) who have provided inaccurate Importer of Record (IOR) information on file with CBP. The publication of this notice signifies that CBP is moving swiftly to implement the June 3, 2026, Executive Order (EO) 14411, "Strengthening Customs Enforcement."
In order to obtain an IOR number and begin importing goods into the United States, individuals or entities (or a customs broker acting on behalf of an individual or entity) must provide identifying information, including a physical address, an email address, a phone number and a tax identification number on CBP Form 5106.
According to the notice, all information on CBP Form 5106 MUST be accurate, complete and belong directly to the IOR. Specifically listed items subject to this notice include the following:
- Physical address: Must be the IOR's actual business or individual location. Registered agent addresses, broker addresses, freight forwarder addresses, P.O. boxes and business service centers are not acceptable.
- Email address: Must be valid and belong to the IOR. A customs broker or third-party email address may not be substituted.
- Phone number: Must be valid and belong to the IOR. A customs broker or third-party number may not be substituted.
- EIN/SSN: Must belong to the IOR directly.
- Valid power of attorney: A customs broker must hold valid power of attorney executed directly with the IOR, not through an intermediary.
CBP has begun verifying IOR information on file for accuracy. Beginning on September 18, 2026, if CBP determines that an IOR or its customs broker has failed to provide complete and accurate information, CBP will immediately void the IOR number. This action could have significant potential impacts for importers, because a valid IOR number is required to import goods into the United States. In addition, this could potentially impact an importer's ability to receive refunds on CBP bills, including those for IEEPA tariff refunds. CBP also signaled it intends to enforce compliance through various mechanisms, including the False Claims Act. CBP's Notice indicates that it intends to apply a strict interpretation, and that it may not give leniency to importers with an inaccurate IOR profile resulting from outdated information or clerical errors.
We recommend that importers reach out to their customs brokers to review their IOR information on file with CBP to ensure it is accurate and up-to-date, and take action if necessary, before September 18, 2026.
For more information on this Notice or the Customs Enforcement EO, please contact Elsa Manzanares, Guy Smith, Ogbo Ossai, Nerissa Hamilton-vom Baur, Matthew Montoya or the Stinson LLP contact with whom you regularly work.
