Importer of Record Voided: Exporter Checklist

Commercial invoice card showing a consignee field, with the line: your buyer's number can be voided" />

If you sell into the United States, one line in a notice CBP published on 19 August 2026 decides whether your next container clears: from 18 September 2026, CBP will void importer of record (IOR) numbers whose CBP Form 5106 details are inaccurate — and a voided number is, in CBP's own words, "invalid for any purpose, including entering imported merchandise into the United States." You are not the party who files that form. You are the party whose goods sit on the dock when it fails. For an exporter shipping 5–30 containers a month, the work this week is one email to your US buyer asking three questions, not a compliance project.

What is CBP actually doing on 18 September 2026?

CBP is checking the identity data every US importer already has on file and switching off the ones that do not hold up. The notice — Accuracy of Importer of Record Data Submitted to CBP, 91 FR 53627 — says CBP "is comprehensively reviewing the CBP Form 5106 information on file for IORs for accuracy," and that beginning on 18 September 2026, where information is incomplete or inaccurate, "CBP will void the IOR number."

Form 5106 is the Create/Update Importer Identity Form. Under 19 CFR 24.5 it is how anyone gets an importer number in the first place, and it carries six required elements: importer name; IRS Employer Identification Number, Social Security Number or CBP-assigned number; mailing address; physical location address if different from the mailing address; phone number; and email address.

This is not the routine housekeeping sweep that removes importers who have not filed an entry in a year. It is a separate action under the same order. Both trace to Executive Order 14411, Strengthening Customs Enforcement, 91 FR 35125, signed 3 June 2026, whose Section 2(e) directs DHS within 180 days to update the IOR registry by "removing inactive IORs; confirming active IORs are compliant with all applicable regulations and disclosures; and creating risk-based tiers for IORs." The August notice is the second of those three — the accuracy pass, aimed at importers who are very much active.

Does this affect you if you are the exporter, not the importer?

Two ways, and the second one is the one people miss.

If you sell on delivered terms — DDP, or any arrangement where you or an entity you named takes on US entry — then you are the IOR, or you chose it. Your Form 5106 is the one under review. Foreign sellers routinely file that form with a US service provider's address because they have no US premises, and that is exactly the pattern the notice disqualifies.

If you sell FOB or CIF and your buyer is the IOR, nothing about your paperwork is defective and your container still stops. A voided number cannot make entry. Your buyer will not learn this from you; CBP says it will send written notice "to the email address the IOR most recently submitted to CBP" — which, when the email on file is the problem, is a loop that closes on nobody. On a long ocean leg, a container you load in the first week of September is still at sea when this starts.

Which Form 5106 details now disqualify an importer?

The notice is unusually specific, and the specifics are the parts most likely to be wrong on an SME's filing. Quoted from the notice:

Physical address — "must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center, or an address of another person or entity."
Email address — "must be valid and belong to the IOR. Customs brokers or third parties may not supply their own email address, or the email address of another person or entity, in place of the IOR's email address."
Phone number — "must be valid and belong to the IOR."
Power of attorney — a broker filing on the importer's behalf must hold a POA "executed directly with the IOR, not via a freight forwarder or other third party," per 19 CFR 111.36(c)(3).

Read those four together and a common small-shipper setup fails all of them at once: the forwarder arranged everything, the forwarder's address went on the form, the forwarder's contact details went on the form, and the POA was papered through the forwarder rather than signed between importer and broker. That arrangement was normal. From 18 September it is a voided number.

What should you check before 18 September 2026?

Send this to whoever handles US entry on your account — your buyer, your US subsidiary, or your broker. It is five questions, and it does not require you to see anyone's tax data.

#	What to confirm	Fails if
1	Who is the IOR of record on our shipments — the buyer, us, or a third party?	Nobody on the thread can answer it in one line
2	Is the physical address on Form 5106 the importer's own premises?	It is the broker's, the forwarder's, a registered agent's, a P.O. box, or a mail-service suite
3	Do the email address and phone number on file belong to the importer?	They route to the broker or forwarder instead
4	Is the customs POA signed directly between importer and broker?	It was arranged through a forwarder or other intermediary
5	Does the importer name and address on our commercial invoice match the Form 5106 record exactly?	Legal entity name, suffix, or street address differ between the two

Row 5 is the one that belongs to you rather than to them, and it is the one nobody owns. CBP also flagged what is coming after this pass: Section 2(a) of the same order directs new importer eligibility rules within 180 days, including minimum bond coverage and disclosures of "anticipated import volumes, year organized, ownership and beneficial ownership disclosures, business affiliation disclosures, and domestic asset disclosures." Section 2(b)(i) separately directs CBP to prohibit a foreign IOR from filing informal entry. If your US route depends on a foreign IOR, that sentence is the one to plan around.

What does this have to do with your export documents?

The importer's identity is not a single field in a single system. It is repeated across the set you issue for every shipment: the commercial invoice names the importer or consignee, the packing list repeats it, the bill of lading carries consignee and notify party, and a certificate of origin names the consignee again. CBP is now treating the identity record as something that must survive scrutiny — and an entry filed against a 5106 record that says "Acme Corporation, 14 Mill Road" while your invoice says "Acme Corp., c/o Global Freight Services" is inviting the review to land on your shipment.

This is the same failure that document mismatches across a shipment set cause on any other field — quantity, value, description. What is new is that the party record itself is now enforced, on a date. If you want the field-level baseline for the US side, our notes on what US customs requires on a commercial invoice and on which fields must match between the invoice and packing list cover the fields this touches. The broader shape of EO 14411 for exporters — the cross-checking of what you filed with your own customs authority — is in our earlier piece on the new US customs rule on foreign exporter documentation.

What does ovrseas do here, and what does it not do?

Plainly: ovrseas does not file CBP Form 5106, does not make customs entry, does not hold a power of attorney, and cannot tell you whether an importer number is currently valid. Those are your broker's job and CBP's system of record. Nothing in this article is legal or customs advice; the notice itself is linked above and it is short enough to read.

What ovrseas does is narrower. You enter the consignee and importer once on the master file for a shipment, and that party block is carried into the commercial invoice, the packing list, the certificate of origin and the rest of the document set without being retyped. That removes exactly one class of problem from row 5 above: the version of the importer's name and address that drifts because someone typed it again in a hurry. It does not verify that the block is correct — only that it is the same everywhere you send it.

If you are re-keying the same party into four documents per shipment today, see what ovrseas costs and try it on your next shipment set.

Sources

U.S. Customs and Border Protection, Accuracy of Importer of Record Data Submitted to CBP, 91 FR 53627 (19 August 2026) — enforcement date, voiding, address/email/phone/POA requirements.
Executive Order 14411, Strengthening Customs Enforcement, 91 FR 35125 (signed 3 June 2026) — Sections 2(a), 2(b)(i) and 2(e).