REGULATORY UPDATE: U.S. Customs and Border Protection (CBP) Enhances Verification of Importer of Record Information
U.S. Customs and Border Protection (CBP) has increased its verification of Importer of Record (IOR) information maintained through CBP Form 5106. As a result, importers may receive requests from their customs broker to review, update, or complete Form 5106 to ensure CBP records remain accurate and up to date. Effective September 18, 2026, CBP may take enforcement action where Importer of Record information is found to be inaccurate or incomplete, including voiding an IOR number.
What is CBP Form 5106?
CBP Form 5106 is the form used to establish and maintain Importer of Record information with CBP. It contains key importer information, including:
- Legal entity name
- Tax identification number
- Mailing address
- Physical address
- Primary phone number
- Primary email address
What should importers do?
If contacted by your customs broker, review and confirm that your Form 5106 information is accurate and current. Attention should be paid to legal entity details, addresses, phone numbers, and email contacts, as these are increasingly being verified by CBP.
These requests are intended to ensure Importer of Record information held by CBP remains accurate and to reduce the risk of import delays or disruptions.
Marken stays committed to supporting clients in navigating the regulatory and trade landscape of the global clinical supply chain. For more information or if you have any questions, contact our team at tradecompliance@marken.com.
