An agreed freight rate does not establish import readiness. The importer and its broker should resolve identity-record questions before the exporter commits the cargo to a departure.
What CBP announced
CBP’s August 19 notice states that enhanced enforcement began on September 18, 2026. An inaccurate or incomplete Form 5106 record may lead to an importer of record (IOR) number being voided and unavailable for import entry. The announcement concerns importer identity data; it does not create a new freight service or tariff. [1]
The record must contain the importer’s accurate physical address, email and telephone number, rather than substituting a third party’s contact information. The notice also addresses powers of attorney executed directly between the IOR and customs broker. [1]
Preparing the importer file
For a new entity or a business that has changed its details, ask the licensed broker to check the legal name, importer identifier and current registration. Record any correction needed, who will submit it and how completion will be confirmed. This is a recommended preparation step, rather than a separate CBP filing deadline.
Keep the buyer, seller, importer and receiving warehouse distinct in the shipment file. Match the invoice and clearance instructions to the confirmed importer. A warehouse receiving address, including an FBA destination, does not by itself identify the party assuming import responsibility.
Dispatch and exception handling
Before collection, obtain the broker’s confirmation of the filing arrangement and unresolved document requirements. Agree the delivery scope separately: customs release, terminal collection and the receiving appointment are different handoffs. A DDP quote should identify how each will be handled.
If CBP voids an IOR number, its notice explains the basis and the process for requesting reestablishment. Coordinate with the authorised broker and revise the cargo plan against the actual clearance position. The announcement does not justify promising a fixed restoration period. [1]
PUBLIC REFERENCES