On September 18, 2026, U.S. Customs and Border Protection begins voiding importer of record numbers where the information on file is inaccurate or incomplete. Not suspending. Voiding. A voided number is invalid for every purpose, including making entry, which in practice means cargo stops at the port.
The notice was published in the Federal Register on August 19, 2026 (federalregister.gov) and appears on CBP's own site in the Customs Bulletin and Decisions, Vol. 60, No. 26, September 2026 (cbp.gov), under the heading Accuracy of Importer of Record Data Submitted to CBP. It is short, it is not a proposal, and there is no phase-in.
What CBP Is Checking
The information in question is what sits on your CBP Form 5106, the record that establishes who you are as an importer. Five elements have to be correct and have to belong to the importer:
The physical location address. Not a post office box, and not a third party's address.
The email address.
The phone number.
The IRS Employer Identification Number, or a Social Security number where the importer of record is an individual rather than a company.
That is the whole list, which is what makes this worth ten minutes of attention. There is nothing subtle in it. The reason it will catch people is not complexity. It is age.
The Address Is Where Most of This Will Land
A Form 5106 is filed once, usually when a company starts importing, often by a customs broker on the importer's behalf during a week when everyone is busy. Then it sits.
Companies move. Companies change name, change broker, change the person whose email went on the form. A number registered in 2015 to an office you left in 2019, with the email address of a buyer who resigned in 2022, has been working perfectly well ever since, because nothing has ever tested it.
Two patterns are worth checking specifically, because both are common and both are exactly what the notice is aimed at. The first is a post office box in the address field. The second is a broker's or agent's address standing in for the importer's own. Neither satisfies a requirement for the importer's physical location, and both were unremarkable practice for years.
The Part Nobody Is Mentioning
CBP will notify a voided importer in writing, at the email address submitted on the form, and that notice explains the basis and how to request reestablishment.
Read that twice. The notice goes to the address on the record. If the email address is the element that is out of date, the warning is delivered to a mailbox nobody opens, and the first anyone hears about it is a shipment that will not clear.
That inverts how this should be prioritised. The address is the element most likely to be wrong; the email is the element whose being wrong stops you finding out. If only one gets checked this week, it is probably the email.
What Voided Actually Means
It is worth being precise, because "voided" sounds administrative and is not.
The number stops working for everything, entry included. There is no grace period in the notice and no provision for goods already in transit. Merchandise arriving against a voided number is merchandise that cannot be entered, and everything that follows from that — demurrage clocks, storage, a delivery date already promised to a customer — happens while the paperwork is sorted out.
The importer of record is a role with legal responsibility attached, which is the same reason classification cannot be handed to your factory. It is your registration, and it is your problem when it lapses.
What to Do This Week
Ask your customs broker to pull your current Form 5106 data and send it to you as it appears in CBP's records, rather than as anyone remembers it. That is a one-line email and brokers can retrieve it.
Then check the five elements against reality. Is the physical address the place your business actually operates, rather than a mailbox or your broker's office. Is the email one somebody reads. Is the phone answered. Is the EIN right, and does the legal name attached to it match what you file under.
Where something is wrong, an updated 5106 corrects it. The form and CBP's guidance sit at https://www.cbp.gov/trade/programs-administration/entry-summary/cbp-form-5106, with a frequently asked questions page at https://www.cbp.gov/trade/programs-administration/entry-summary/cbp-form-5106/importer-createupdate-identity-5106-faq. CBP has automated the application for companies that already have one on file, and it can be submitted online through the Automated Commercial Environment, the system customs entries are filed in, at https://ace-accounts.cbp.gov/s/importer-form.
If It Has Already Happened
Reinstatement runs through IORProgram@cbp.dhs.gov. Either the importer or an authorised customs broker can request it, and CBP requires corroborating documentation establishing identity.
That is a real path, and it is a slower one than fixing the record beforehand.
Why This Is Happening Now
The notice implements Executive Order 14411, Strengthening Customs Enforcement, and cites the customs statutes at 19 U.S.C. 1484 and 4320. The stated reasoning is that accurate information about importers of record is essential to enforcing customs and trade law, which reads as boilerplate until you place it next to everything else happening this year: tariffs at levels that make misdeclaration worth money, transshipment enforcement, and a proposal to give CBP visibility into every party in an import supply chain.
Seen that way it is not really an administrative tidy-up. Knowing who is actually importing is the foundation the rest of it stands on, and a registration that points at a mailbox and a dead mailbox is not much of a foundation.
None of which changes what you do about it. Somebody should look at your 5106 before the eighteenth.
This is general commentary, not legal or customs advice. Confirm your own position with a licensed customs broker or qualified trade counsel, and read the notice itself rather than any summary of it, this one included.
So — who in your business actually knows what is on your Form 5106 right now, and what do you use today to keep registrations, certifications and renewals from going quietly stale until something stops at a port?