U.S. Customs and Border Protection (CBP) is introducing enhanced enforcement measures as part of the implementation of Executive Order 14411, Strengthening Customs Enforcement. From September 18, 2026, CBP will begin enhanced verification of Importer of Record (IOR) information and may immediately void IOR numbers where information held on CBP Form 5106 is found to be inaccurate or incomplete.

The measures represent an important step in a wider move towards increased importer accountability and stronger customs enforcement in the United States.

Businesses importing into the U.S. should review their Importer of Record information now and ensure the details held by CBP are complete, accurate and up to date.

Action required

U.S. Importers of Record should review their CBP Form 5106 information before September 18, 2026, paying particular attention to their physical business address, email address, telephone number and Customs Power of Attorney arrangements.

What is changing from September 18, 2026?

CBP published a Federal Register notice on August 19, 2026 confirming enhanced enforcement procedures designed to verify the accuracy of information provided by new and existing Importers of Record.

From September 18, 2026, if CBP determines that information provided on CBP Form 5106 – Create/Update Importer Identity Form is inaccurate or incomplete, it may immediately void the associated IOR number.

A voided IOR number becomes invalid for customs purposes, including the entry of imported merchandise into the United States.

The requirements apply to information submitted directly by an Importer of Record as well as information submitted on its behalf by a licensed customs broker.

What information is CBP reviewing?

Importers should ensure that all information associated with their Form 5106 is accurate and remains up to date.

CBP has specifically highlighted the importance of verifying:

• Physical business address – this must be the actual physical location of the Importer of Record and cannot be the address of a registered agent, customs broker, freight forwarder, P.O. box, business service centre or another person or entity.
• Email address – the email address must be valid and belong to the Importer of Record.
• Telephone number – the telephone number must be valid and associated directly with the Importer of Record.
• Importer identification information – including the relevant Employer Identification Number (EIN), Social Security Number (SSN) or CBP-assigned number, as applicable.
• Other Form 5106 information – importers should ensure all information submitted to CBP remains complete and accurate.

Importantly, contact information belonging to a customs broker, freight forwarder, registered agent or other third party should not be provided in place of the Importer of Record's own details.

Customs Powers of Attorney also under scrutiny

CBP has also reiterated requirements surrounding Customs Powers of Attorney (POAs).

Where a customs broker submits information or conducts customs business on behalf of an Importer of Record, the broker must hold a valid POA executed directly with the IOR.

CBP has specifically stated that a customs broker's POA must be executed directly with the Importer of Record rather than through a freight forwarder or other third party.

Importers should therefore review not only the information held on their Form 5106 but also ensure that appropriate and current authorisations are in place with their customs brokers.

Why is CBP making these changes?

The measures form part of the implementation of Executive Order 14411 – Strengthening Customs Enforcement, issued on June 3, 2026.

The Executive Order sets out a broader programme intended to strengthen U.S. customs enforcement, improve importer accountability and ensure that Importers of Record can be properly identified and held responsible for their customs and trade obligations.

The Order directs U.S. authorities to strengthen several areas of importer oversight, including importer eligibility, bonding requirements, importer identification and disclosure requirements, and compliance verification.

The increased scrutiny of Form 5106 information should therefore be viewed as part of a broader shift towards greater importer transparency, verification and accountability.

Further regulatory and procedural developments are expected as CBP and other U.S. authorities continue implementing the Executive Order.

What should U.S. importers do now?

Businesses acting as Importers of Record should take the opportunity to review their information before enhanced enforcement begins on September 18.

Importers should:

1. Review their CBP Form 5106 information and confirm that all details remain accurate and complete.
2. Verify their physical business address, telephone number and email address, ensuring each belongs directly to the Importer of Record.
3. Check that third-party information has not been used in place of the IOR's own contact information.
4. Confirm that a valid Customs Power of Attorney is in place with any customs broker acting on their behalf.
5. Review their ACE Portal records and arrange for any inaccurate or outdated information to be corrected promptly.

Businesses should not assume that information remains correct simply because their IOR number has been used successfully in the past. CBP has confirmed that it is reviewing information held for existing as well as new Importers of Record.

What happens if an IOR number is voided?

From September 18, where CBP determines that Form 5106 information is inaccurate or incomplete, it may immediately void the associated IOR number.

CBP states that it will issue written notification to the email address most recently provided by the IOR, explaining the basis for the decision and how reestablishment of the IOR number can be requested.

A voided IOR number cannot be used to enter imported merchandise into the United States until it has been successfully reestablished.

This makes maintaining accurate importer information particularly important for businesses seeking to minimise the risk of disruption to their U.S. import activity.

What should importers expect next?

The enhanced Form 5106 verification is one element of a broader programme of U.S. customs reform. Executive Order 14411 also directs authorities to strengthen importer eligibility, bonding, disclosure, vetting and compliance requirements.

Foreign Importers of Record (FIORs) should pay particular attention to the changes. Under the new requirements, foreign IORs will need to review their eligibility for CTPAT validation or ensure they are working with a CTPAT-validated customs broker in order to continue acting as an Importer of Record in the United States.

CBP has also introduced increased due diligence requirements for CTPAT-validated customs brokers working with foreign IORs. This includes more comprehensive verification of an importer’s legal identity, ownership structure, business affiliations, U.S. assets and compliance history, as well as its ability to pay applicable duties, taxes and fees. Brokers will also be expected to verify information relating to supply chains, product classification, valuation and country of origin.

Foreign IORs should therefore review their current arrangements and be prepared to provide their customs broker with more detailed information as part of onboarding and ongoing compliance procedures.

Importers of Record will also be required to maintain “good standing” with CBP, with those that lose good standing potentially prohibited from importing goods.

Businesses importing into the U.S. should therefore expect greater importer verification and accountability as CBP continues implementing Executive Order 14411.

How Woodland Group can support you

Woodland Group's U.S. customs brokerage and trade compliance teams can support customers in understanding their customs obligations and reviewing the information required for U.S. import activity.

Customers using Woodland's U.S. customs brokerage services who have questions regarding their Importer of Record information, CBP Form 5106 or Customs Power of Attorney arrangements should contact their Woodland representative.