CBP Starts Voiding Importer Numbers on September 18

Starting September 18, 2026, US Customs and Border Protection can void your importer of record number the moment it decides your paperwork is wrong, and it does not have to warn you first. If that happens mid-shipment, your cargo sits at the port with no valid importer number to release it. There is no grace period once the number is voided.1

This is not a proposal still working through comment periods. CBP published a general notice in the Federal Register on August 19, 2026, and the 30-day clock runs out on September 18.2 If you import goods into the US under your own name or an entity you control, this is worth ten minutes of your time this week.

What's actually changing

Every importer of record has a number tied to CBP Form 5106, the "Create/Update Importer Identity Form." It links your legal name, tax ID (EIN or SSN), mailing address, physical address, phone number, and email to the number CBP uses to process every entry you file.3

Beginning September 18, CBP will immediately void that number if the Form 5106 information on file is inaccurate or incomplete. A voided number cannot be used for anything, including making entry. CBP says it is already reviewing the 5106 data it holds for every active importer, not waiting for a new filing to surface problems.1

The most common failure points, based on CBP's own guidance, are dull but costly:

• Address mismatches: the physical address on file does not match the legal business address on IRS records.

• Stale contact info: the phone number or email is outdated, so CBP cannot reach you before or after it acts.

• Wrong tax ID: the EIN or SSN on the 5106 does not actually belong to the entity acting as importer of record.

• Shared or borrowed numbers: a broker or affiliate filing under someone else's importer number instead of the importer's own.

Why CBP is doing this now

This is one of the first concrete enforcement actions under Executive Order 14411, "Strengthening Customs Enforcement," which President Trump signed on June 3, 2026.4 The order directs the Department of Homeland Security to confirm that every active importer of record is who they say they are and is meeting basic compliance obligations, with deadlines of 45, 90, and 180 days from signing for follow-through.5

Form 5106 accuracy is the opening move, and more is coming. The same executive order requires every importer of record, foreign or domestic, to hold a customs bond, a minimum level of tangible US-based assets, or both, and directs CBP to raise minimum bond coverage requirements.4 Foreign importers of record lose access to continuous bonds for most entries and face new restrictions on informal entry.5 The order also sets a penalty floor of 50% on mitigated customs violations, so CBP can no longer settle a penalty case for a token fraction of the original assessment.6 Expect the bulk of these rules to phase in by early December, the 180-day mark from the June 3 signing.

What happens if your number gets voided

CBP will send written notice to the email address on file explaining why the number was voided.1 That is the catch: if your email on file is wrong, which is one of the exact issues that triggers a void, you may not see the notice until a shipment is already stuck. A voided number blocks new entries immediately. Freight already on the water or in the air does not turn around, but it cannot clear once it lands.

Reinstating a voided number is not automatic. CBP's process requires emailing an un-void request with supporting documentation to its bond compliance team, and there is no published turnaround time.1 For a business with inventory timed to a specific vessel or a retail deadline, even a few days of delay at the port is real money: demurrage, detention, and a missed sell-through window heading into Q4.

How to check your Form 5106 before September 18

You do not need to wait for a notice to act. Do this now:

• Confirm your legal name and address match IRS records exactly. A DBA, an old office address, or a suite number that changed after a move are common mismatches.

• Verify the EIN or SSN on file belongs to your entity, not a parent company, a former importer of record, or a broker's own number used as a shortcut.

• Update the phone number and email to ones your team actually monitors, not a former employee's inbox or a shared line nobody checks.

• Ask your customs broker to pull your current 5106 record and confirm it matches your actual business records. Brokers with ACE Portal access can submit corrections electronically.

If you find an error, file an updated Form 5106 through your broker or CBP's Automated Commercial Environment (ACE) Portal well before September 18. Waiting until the deadline to check means finding out the hard way, with a shipment already stopped.

Frequently asked questions

Does this apply to me if I use a freight forwarder or customs broker?
Yes. The importer of record number belongs to the legal entity buying the goods, not to the forwarder or broker filing the paperwork. Whoever's name is on the entry is the one whose 5106 has to be accurate. A good customs brokerage partner can pull your record and flag mismatches, but the underlying business information is yours to get right.

Does this affect ocean freight, air freight, or both?
Both. A voided importer number blocks entry regardless of mode, whether that's ocean freight containers waiting at the port or air freight shipments landing at an airport of entry.

What if my LLC changed addresses or ownership recently?
That is exactly the scenario CBP is targeting. If your registered address, EIN, or officer information changed and your Form 5106 was never updated to match, treat this as urgent.

Is this related to the customs bond increases importers have been hearing about?
It's part of the same executive order but a separate, faster-moving piece. Bond and asset requirement changes need formal rulemaking and will phase in over months. The Form 5106 accuracy check is already live and enforced starting September 18.

The bottom line

None of this requires new paperwork you haven't already filed once. It requires making sure what you filed is still accurate. That's a low bar, but CBP's own review already found enough problems to justify a blanket enforcement notice covering every active importer number in the country. Check yours this week, not after a container is stuck at the port with no importer number to release it.

If you're not sure your customs setup can withstand this level of scrutiny, or you want a broker who checks this kind of thing proactively instead of after a shipment is stuck, get in touch with Cubic. We handle customs brokerage and freight together, so import compliance isn't something that only gets checked after it breaks.