What triggers CBP to void an importer-of-record number?

CBP voids IOR numbers when Form 5106 submissions contain inaccurate or incomplete information. Common triggers include nonresident importers using a customs broker's address instead of actual U.S. premises, missing or incorrect company details, outdated records that have not been updated in years, and customs brokers listing their own contact information instead of the importer's actual address or phone number. The agency conducts comprehensive reviews but does not publicly disclose specific deficiency thresholds.

How will importers know if their IOR number has been voided?

CBP will send written notification to the email address most recently submitted by the importer and will copy the customs broker that most recently filed an entry on the importer's behalf. However, one of the biggest operational risks is that an importer may not discover the voiding until a shipment is already moving through the supply chain, potentially resulting in cargo being held at ports of entry.

What happens to cargo if an importer's IOR number is voided mid-shipment?

Once an IOR number is voided, it cannot be used for any purpose, including making entry into the United States. Affected cargo will be stranded at ports of entry until the importer can reestablish its IOR number with CBP. During this period, cargo will accrue port-related storage costs, demurrage fees, and potential dwell charges, significantly increasing landed costs.

Can importers correct deficiencies before their numbers are voided?

No. CBP's enforcement regime does not include a warning period or opportunity to correct information before voiding occurs. Importers must seek to have their numbers reestablished after CBP takes enforcement action, which requires engaging with the agency to demonstrate compliance with Form 5106 requirements.

What responsibilities do customs brokers face under this enforcement action?

Customs brokers must conduct due diligence to ensure importer information is accurate and complete. Brokers cannot substitute their own contact information for customers' actual details, must obtain power of attorney directly from importers (not through freight forwarders or third parties), and face monetary penalties and enforcement action if they provide inaccurate or misleading information. A brokerage with its own address across hundreds of client records could face hundreds of compliance defects.

Trade Policy & Tariffs

High Impact

CBP's Importer Crackdown Threatens to Strand Thousands of Shipments

Sep 21, 2026

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The signal

S. Customs and Border Protection agency has launched a comprehensive enforcement initiative that automatically voids importer-of-record (IOR) numbers containing inaccurate or incomplete information submitted on Form 5106. This policy, which took effect in August 2026, applies retroactively to existing importers and prospectively to new registrations, creating an immediate supply chain vulnerability for companies that may discover their IOR status has been revoked only after shipments are already in transit. The agency provides no advance warning period and no opportunity to correct deficiencies before voiding occurs—instead, importers must seek to reestablish their numbers after CBP takes enforcement action.

The operational risk extends across the entire import ecosystem. S. premises, foreign sellers operating as importers of record in delivered-duty-paid arrangements, e-commerce businesses using third-party fulfillment centers, and smaller importers with outdated records face particular exposure. Customs brokers face heightened scrutiny for due diligence failures, and brokers who have substituted their own contact information across hundreds of client records could face massive compliance defects and potential monetary penalties.

S. import chains is common. This enforcement action represents a structural shift in regulatory posture rather than a temporary initiative, signaling CBP's commitment to verifying importer identities as part of broader border security objectives. The lack of transparency regarding the number of voided IOR numbers exacerbates uncertainty, and companies currently cannot assess their exposure until notification arrives.

#cbp-enforcement

#importer-of-record

#customs-compliance

#cross-border-logistics

#supply-chain-disruption

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What This Means for Your Supply Chain

Simulation Suggestion

immediate

What if 20% of your supplier base faces IOR voiding within 90 days?

Simulate a scenario where inaccurate importer records cause 20% of your active suppliers' IOR numbers to be voided without warning, resulting in shipments being held at U.S. ports for 7-14 days while reestablishment is processed. Model the impact of 15-25% increase in per-unit landed costs due to port demurrage, storage fees, and expedited re-clearance efforts across your U.S.-bound import volume from Mexico and Canada.

Run this scenario

Simulation Suggestion

this month

What if you must audit and remediate 500+ supplier IOR records within 60 days?

Simulate the operational burden of conducting due diligence on all active supplier IOR registrations to identify deficiencies before CBP enforcement action, including coordinating with customs brokers, validating importer data accuracy, obtaining updated Form 5106 submissions, and addressing compliance gaps. Model the resource allocation required—compliance staff, broker coordination time, documentation gathering—and potential supply disruption if critical suppliers cannot clear their records in time.

Run this scenario

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