August 20, 2026
U.S. Customs and Border Protection (CBP) has announced enhanced enforcement measures to verify the accuracy of Importer of Record (IOR) information maintained in its systems. The initiative is being implemented as part of Executive Order 14411, Strengthening Customs Enforcement, and represents one of the most significant importer registration enforcement actions in recent years. CBP is conducting a comprehensive review of both new and existing Importer of Record information to ensure the accuracy and integrity of data submitted to the agency.
CBP is comprehensively reviewing the CBP Form 5106 information on file for Importers of Record to verify its accuracy. Beginning September 18, 2026, CBP may determine that an Importer of Record or a customs broker acting on behalf of an importer has failed to provide complete and accurate information. In such cases, CBP may void the Importer of Record number, rendering it invalid for all customs purposes, including filing entries for imported merchandise into the United States. CBP has also stated that it may pursue additional enforcement actions, as appropriate.
CBP emphasized that Importers of Record and customs brokers must ensure that all information submitted through CBP Form 5106 is accurate, complete, and maintained on an ongoing basis. The party certifying a CBP Form 5106 is responsible for verifying the information prior to submission and may face legal consequences for knowingly providing inaccurate information. CBP specifically references potential liability under 18 U.S.C. §1001 for false statements and notes that inaccurate importer data may also create exposure under the False Claims Act and other applicable laws.
CBP identified several key data elements that will receive heightened scrutiny during its review process.
Physical Address: The physical address listed on CBP Form 5106 must be the actual physical location of the Importer of Record. CBP specifically states that the reported address cannot be a customs broker's office, a freight forwarder's address, a registered agent's location, a business service center or virtual office, a P.O. Box, or the address of another person or entity. Importers should review their existing records immediately to ensure the physical address on file accurately reflects the company's actual place of business.
Email Address: The email address submitted to CBP must belong directly to the Importer of Record. Brokers, consultants, freight forwarders, and other third parties may not substitute their own email address in place of the importer's email address.
Telephone Number: The telephone number reported to CBP must belong directly to the Importer of Record. Third parties should not provide their own contact numbers or the contact information of another entity in place of the importer's actual phone number.
Historically, many importers have relied on customs brokers or other service providers to manage importer registration information. CBP's notice makes clear that Importers of Record remain responsible for ensuring the accuracy of the information submitted on their behalf. With CBP beginning enforcement actions on September 18, 2026, importers should treat a comprehensive Form 5106 review as an immediate compliance priority.
Crane Trade Consulting recommends that importers take immediate action to review their importer registration information before the September 18, 2026 enforcement date, review all CBP Form 5106 information currently on file, verify that the legal entity name exactly matches corporate records, confirm that the physical address reflects the company's actual place of business, validate that the email address belongs directly to the Importer of Record, confirm that the telephone number belongs directly to the Importer of Record, ensure customs brokers maintain accurate importer information in their systems, update CBP records promptly if corporate information has changed, and review internal controls governing importer registration and maintenance activities.
Organizations that have undergone mergers, acquisitions, ownership changes, legal entity changes, address changes, EIN updates, or corporate restructuring should ensure that CBP records accurately reflect their current business information.
Disclaimer
This advisory is provided for informational purposes only and does not constitute legal advice. Companies should consult legal counsel and trade compliance professionals regarding their specific compliance obligations.
Crane Trade Consulting can assist importers with CBP Form 5106 reviews and updates, Importer of Record compliance assessments, Customs broker management reviews, Import compliance audits, corporate change impact assessments, Customs recordkeeping reviews, Internal control evaluations, Importer registration governance programs. For additional consultation on a case-by-case basis, please contact our Trade Advisorory team.
Let one of our client advocates build a solution that fits your logistics needs.
1500 Rankin Road
Houston, TX 77073
+1 888-870-2726
