Effective September 18, 2026, U.S. Customs and Border Protection (CBP) has officially begun enhanced verification of Importer of Record (IOR) information, based primarily on the accuracy of CBP Form 5106 filing data.

This is not an ordinary notice; it is a compliance action that will directly affect your U.S. shipments, customs clearance, inventory, and cash flow.

Key Points of the New Rule

CBP now requires that information on Form 5106 be “accurate, complete, and directly attributable to the IOR entity.” If information is found to be false or incomplete, the IOR number may be invalidated immediately, with no remediation grace period.

Key verification items include:

· Physical operating address: it cannot be a registered agent, customs broker, freight forwarder, P.O. Box, virtual office, or other third-party address.

· Email and phone: they must belong to the IOR itself or its entity, and cannot use contact information of a freight forwarder, customs broker, or other third party.

· Company name and EIN: must match IRS registration information; borrowing or attaching another party’s tax ID is not allowed.

· POA authorization: when a customs broker submits Form 5106, it must hold a valid POA directly signed by the IOR, and cannot be transferred through a freight forwarder or third party.

Direct Impact on Sellers

If an IOR is invalidated, the following may occur:

· Goods in transit cannot be cleared after arrival;

· Demurrage, storage, and container charges may accrue;

· Goods may be detained or returned, and in serious cases may be seized;

· If intentional false filing is found, it may lead to civil or even criminal liability.

Urgent Seller Self-Check Action List

· Confirm whose IOR is being used for the current shipment. Do not just ask “can it be cleared?” Ask clearly: who is the IOR entity, whose EIN is used, whose address is listed, and whose email and phone are used.

· Verify Form 5106 information. Focus on whether the company name, EIN, physical address, mailing address, phone, and email are accurate and belong to the IOR entity.

· Stop using high-risk IORs. Shared IORs, third-party addresses, freight forwarder email/phone, and POAs transferred through third parties are high risk.

· Re-sign compliant POAs. Ensure the customs broker holds a POA directly signed by the IOR, not signed or forwarded by a freight forwarder.

· Allow buffer time before shipment. Inspection rates are higher during peak season; if an IOR issue arises, recovery time is uncertain. Do not ship against warehouse or delivery deadlines.

If you are currently using an IOR provided by a freight forwarder or a “dual-clearance tax-included” channel, it is recommended to request as soon as possible: IOR entity name, EIN, Form 5106 filing information, POA signer, and bond type. If the other party cannot clearly explain these, the shipment should not continue under the original plan.