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CBP to Increase Scrutiny of Importer of Record Information

September 9, 2026 Avalon

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Last month, U.S. Customs and Border Protection (CBP) announced enhanced enforcement measures designed to verify the accuracy of Importer of Record (IOR) information submitted on CBP Form 5106. Beginning September 18, 2026, CBP may immediately void an IOR number if it determines that the information on file is inaccurate, incomplete, or cannot be verified.

The enforcement is part of CBP's implementation of Executive Order 14411, “Strengthening Customs Enforcement”. It reflects a broader effort to ensure that importers are properly identified, accountable for duties owed, and compliant with U.S. trade laws.

The Federal Register Notice specifically highlighted the importance of maintaining accurate physical addresses, email addresses, phone numbers, and taxpayer identification information. The notice also emphasized that customs brokers must maintain a valid Power of Attorney directly with the importer.

Why Importers Should Review Their IOR Information Now

An invalid IOR number could prevent an importer from entering merchandise into the U.S., potentially disrupting supply chains and creating costly delays. CBP also warned that inaccurate information could expose importers and other parties to additional enforcement actions and legal liability.

Importers should proactively review their CBP Form 5106 records to confirm that all contact information, business addresses, and identification numbers are current and belong directly to the importing entity. Verifying this information now can help avoid interruptions to import operations before CBP's enhanced enforcement program takes effect on September 18.

To help importers and customs brokers navigate these new requirements, CBP has created a specific page dedicated to the implementation of Executive Order 14411. The page contains announcements, answers to common questions, and other resources related to the agency's enhanced enforcement efforts. We encourage importers and customs brokers to review this information regularly and stay informed about the latest CBP updates as the September 18 enforcement date approaches.

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The Quest Newsletter is designed to provide critical information in the transportation industry. Avalon Risk Management is not responsible for the accuracy or reliability of information contained in articles. The reader/user assumes all risk in the use of such information.