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CBP Form 5106: US importer number and the 2026 importer data checks

Every importer of record needs an identification number on file with US Customs and Border Protection, created with CBP Form 5106. Since 18 September 2026, CBP has been checking that information more strictly: a record with a forwarder's or broker's address, borrowed contact details or a power of attorney signed through a third party can be voided immediately, which stops the importer's shipments until it is fixed.

Checked against official sources: 2026-10

At a glance

FormCBP Form 5106, filed with the first formal entry or first request for services; also needed for the ultimate consignee
Number usedIRS employer identification number (EIN); if none, a Social Security number
No EIN or SSNCBP assigns an importer identification number when the form is received
LapseA number not used for one year is removed if no transaction is pending; a new Form 5106 is then needed
2026 enforcementEnhanced checks from 18 September 2026 (CBP notice of 19 August 2026); inaccurate data can lead to immediate voiding
AddressThe physical address cannot be a registered agent, customs broker, freight forwarder, P.O. box or another person's address
ContactsEmail and phone number must be valid and belong to the importer of record
Power of attorneyThe broker's power of attorney must be executed directly with the importer of record, not through a forwarder

What CBP Form 5106 does

Under 19 CFR 24.5, each person, business or other organisation files CBP Form 5106 with its first formal entry or first request for services, and a form is also required for the ultimate consignee. The identification number is the IRS employer identification number or, if there is none, a Social Security number. If the filer has neither, the CBP office receiving the form assigns an importer identification number. Customs brokers can transmit the form electronically through ACE.

A number stays on file for one year from its last use; after that, if no transaction is pending, it is removed and the business must file another Form 5106 before importing again. Importers can also ask CBP to freeze their name and address information through the voluntary freeze program.

What CBP checks since 18 September 2026

What this means for foreign sellers acting as importer

CBP's notice of 19 August 2026, issued to begin implementing Executive Order 14411, says it is enforcing the accuracy of importer of record information more strictly from 18 September 2026. A foreign company importing on DDP terms whose Form 5106 lists a forwarder's or broker's US address or contact details now risks having that record voided, which would stop entries filed under that number.

A foreign seller that wants to remain importer of record should check its Form 5106 with its broker: use its own physical business address and its own email and phone, sign the power of attorney directly with the customs broker, and keep the record active. If a number is voided, the importer can request reestablishment as described in CBP's notice after correcting the data.

Step by step

  1. Ask your customs broker for a copy of the Form 5106 data CBP holds for your importer number.
  2. Replace any forwarder, broker, registered agent or P.O. box address with your own physical business address.
  3. Use your own company email and phone number, and remove contacts that belong to third parties.
  4. Sign the power of attorney directly with the customs broker, not through your freight forwarder.
  5. Have the broker submit the corrected Form 5106 and keep the number in use, or refile if it lapsed after a year.

Documents you usually need

Common problems and how to avoid them

The importer record uses the freight forwarder's US address.

What to do: Replace it with the importer's own physical address; forwarder, broker, registered agent and P.O. box addresses are not accepted.

The power of attorney was arranged by the forwarder on the importer's behalf.

What to do: Execute a new power of attorney directly between the importer of record and the customs broker.

CBP voided the importer number and entries are rejected.

What to do: Correct the Form 5106 data and request reestablishment as explained in CBP's voiding notice.

The importer has not imported for more than a year.

What to do: The number may have been removed; file a new CBP Form 5106 before the next entry.

Sources

  1. Accuracy of Importer of Record Data Submitted to CBP (notice of 19 August 2026) Federal Register, U.S. Customs and Border Protection (CBP)
  2. 19 CFR 24.5: Filing identification number Electronic Code of Federal Regulations (eCFR)

Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.

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Common questions

What is CBP Form 5106?

The form that creates or updates an importer's identity record with US Customs and Border Protection, filed with the first formal entry or first request for services.

Can a foreign company without an EIN get a US importer number?

Yes. If the filer has neither an IRS employer identification number nor a Social Security number, CBP assigns an importer identification number when it receives the form.

What changed for importer of record data in 2026?

From 18 September 2026, CBP enforces the accuracy of Form 5106 data more strictly and can void importer numbers immediately for inaccurate information such as a forwarder's address.

Can I use my freight forwarder's address on Form 5106?

No. The physical address cannot be a registered agent, customs broker, freight forwarder, P.O. box or another person's address.

How long does a US importer number stay active?

It is kept for one year from its last use; if unused and no transaction is pending, it is removed and a new Form 5106 is needed.

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