U.S. Customs and Border Protection (CBP) has issued an important notice, “Accuracy of Importer of Record Data Submitted to CBP,” to strengthen verification of Importer of Record (IOR) data accuracy.

Published in the Federal Register on August 19, 2026, the notice states that CBP will further verify information submitted by new and existing IORs on CBP Form 5106 (Importer Identity Form).

1. What exactly is CBP checking?

Effective September 18, 2026, if CBP determines that IOR information is incomplete or inaccurate, it may invalidate the IOR number, making it unusable for U.S. import clearance.

IOR (Importer of Record) is the party responsible for customs obligations for goods imported into the United States.

For U.S. commercial imports, the IOR must provide identity and business information to CBP. This review does not only check the company name; it will fully examine identity information on Form 5106, including:

① Importer name;

② EIN / SSN / CBP assigned number;

③ Mailing address;

④ Physical address;

⑤ Phone number;

⑥ Email address;

⑦ Company structure, beneficial owners, company officers, and other related information.

In other words, if you use a U.S. company with an address that cannot be proven to have a real connection to the company, or if there are obvious inconsistencies among the company’s EIN, phone number, email, and address, the risk of further review may increase.

2. Why are U.S. addresses a focus?

CBP has very clear requirements for the physical address: it must be the actual location where the business or individual operates.

The following addresses cannot be used as the IOR’s physical address:

① Registered agent address;

② Customs broker address;

③ Freight forwarder address;

④ PO Box;

⑤ Business service center;

⑥ Another individual’s or company’s address.

In other words, having a U.S. address does not mean it qualifies as a CBP-compliant IOR physical address. Email addresses and phone numbers also cannot simply be those of service providers, customs brokers, or third parties. CBP requires these contacts to be valid and belong to the IOR or its business.

Therefore, for companies that need to apply for an IOR and complete U.S. import clearance, the authenticity, verifiability, and connection of the address to the company will become increasingly important.

3. What does it mean for Chinese cross-border sellers?

This policy deserves close attention because it targets both new and existing IORs. CBP is comprehensively reviewing Form 5106 information already on file, not just checking new applicants.

Sellers in the following situations should conduct a self-review before September 18:

1. The U.S. company is registered, but the address on Form 5106 is not its actual business address.

2. A customs broker, freight forwarder, or third-party address is used as the IOR physical address.

3. The email or phone number on Form 5106 actually belongs to a service provider.

4. The EIN, company name, or other information is inconsistent with current business records.

5. The company has changed, but Form 5106 has not been updated in time.

6. A customs broker submitted Form 5106 on behalf of the IOR without a valid direct POA.

CBP also emphasized that when customs brokers submit Form 5106 for clients, they must establish a valid Power of Attorney (POA) directly with the IOR, not indirectly through freight forwarders or other third parties.

Final note:

Once an IOR number is invalidated, it cannot be used for filing U.S. import declarations. CBP will send written notice to the IOR’s most recently submitted email address, explaining the reason and how to apply for reinstatement.

Therefore, cross-border sellers that use a U.S. company as the importer of record should treat Form 5106 information as a “U.S. import identity check-up” before September 18.

This is the risk reminder from Yiju Overseas. Feel free to leave comments and discuss below!