If your business is based outside the United States and acts as its own importer of record, your CBP Form 5106 is now under active CBP scrutiny. Many overseas exporters treated it as a one-off setup form that a broker filled in once. That changed on 18 September 2026, when CBP began reviewing the importer data it holds and voiding IOR numbers whose details don’t hold up.
This guide explains CBP Form 5106 for the non-resident importer: UK and other non-US exporters who ship to the US under their own name. It covers what the form is, who files it, what to prepare, how it fits with your bond and broker, the most common mistakes, and a timeline to work to before 30 November 2026.
It is practical guidance, not legal advice. A Form 5106 is not a licence, an FDA registration or an approval. It is simply how CBP identifies you.
- 18 Sep
- IOR voiding began
- 30 Nov
- EO 14411 deadline
- 6
- Core required data fields
What Is CBP Form 5106?
CBP Form 5106 is the Create/Update Importer Identity Form. Under 19 CFR 24.5, every person or business must file one with its first formal entry, or with the first request for CBP services that will lead to a bill or a refund. A separate Form 5106 is also needed for the ultimate consignee.
It sets up the number CBP links to your entries, bonds, bills and refunds:
- IRS Employer Identification Number (EIN). If you hold one when you file, it automatically becomes your importer number.
- Social Security Number for individuals without an EIN.
- A CBP-assigned number if you have neither. CBP generally issues these to foreign businesses and individuals (block 1E has an “I am not a U.S. Resident” option).
Under 19 CFR 24.5(e), a number left unused for a year (with no outstanding transaction) is removed from CBP’s files, and you would need to file again.
Why Form 5106 Matters More Under EO 14411
Executive Order 14411, signed on 3 June 2026, gave the Department of Homeland Security 180 days to tighten the rules on who can import. That window ends on 30 November 2026. The order directs CBP to require more data from importers of record, including anticipated import volumes, year organised, beneficial ownership, business affiliations and domestic assets. It also directs CBP to remove inactive IORs from its registry and confirm that active IORs meet all applicable disclosures.
CBP’s first public step was a Federal Register notice on 19 August 2026 announcing a full review of Form 5106 data. From 18 September 2026, if the information is incomplete or inaccurate, CBP voids the IOR number, making it invalid for any purpose, including entering goods. If you sell on Amazon.com, our earlier article on why Amazon sellers need a US importer of record under EO 14411 covers the changes to informal entry, bonds and CTPAT. This guide sticks to the form itself.
Sources: Federal Register, EO 14411 | CBP notice 2026-16911 | 19 CFR 24.5
Who Files Form 5106, and How?
The form makes you, the importer, responsible for the information being valid. A broker filing for you is only obliged to pass it on to CBP. There are two routes:
- Through a licensed customs broker using CBP’s Automated Broker Interface (ABI) or the ACE Form 5106 portal. CBP-assigned numbers can be requested through ABI.
- By email to a CBP Center of Excellence and Expertise. Send it to your assigned Center, or if you don’t have one yet, to the Center that covers the tariff classification of your highest-value commodity. CBP’s FAQ says paper submissions typically take two business days to set up a new IOR and five business days for a change of name or address.
If a broker submits the form for you, they must hold a valid power of attorney signed directly with you, the importer. CBP says a POA arranged through a freight forwarder or other third party is not enough.
What Information and Documents to Prepare
Required fields
CBP’s notice lists six core data elements: importer name; EIN, SSN or CBP-assigned number; mailing address; physical location address if different; phone number; and email address. The revised form (version 06/26) also asks for the address type (residence, corporate office, warehouse and so on). It needs a physical address if your mailing address is a P.O. box, and a signed certification with your name, title and date.
Company information: optional, but worth completing
Section 3 is usually optional, but the form warns that leaving it blank “could result in the delay of cargo release or the processing of a refund.” It asks for:
- A brief business description, 6-digit NAICS code and D-U-N-S number
- Year established and any current or previous related businesses
- Primary banking institution
- Certificate or articles of incorporation: the country ISO code and registration number (for a UK limited company, your Companies House number)
- Company officers and beneficial owners with importing and financial knowledge of the business, plus direct contact details (passport details are optional in most cases)
Several of these match the disclosures EO 14411 tells CBP to require, such as year organised and beneficial ownership. In our view, filling them in accurately now is sensible preparation.
Supporting documents to keep ready
- Certificate of incorporation and proof of your registered and trading addresses
- A signed power of attorney made directly with your customs broker
- IRS confirmation of your EIN, if you have one (CBP accepts IRS-issued documents such as a 147C letter when reinstating EIN-based numbers)
How Form 5106 Fits With Your Bond, Broker and IOR Status
The form gives you an identity with CBP, but on its own it doesn’t let you make entry. For formal entries, EO 14411 directs CBP to require that a foreign IOR does not rely on a continuous bond (unless CBP is satisfied that revenue and compliance are protected), and that it is either CTPAT-validated or files through a CTPAT-validated licensed customs broker. It also sets a “good standing” test. IORs that are not in good standing cannot import, and cannot designate a customs broker to act as IOR for them.
Two practical points follow. A change of name or address with an active bond normally needs a bond rider, according to the form’s instructions. And your 5106 data, bond, broker and POA must all describe the same legal entity. Mismatches are exactly what an accuracy review catches.
Common Form 5106 Mistakes That Put Your IOR Number at Risk
- Borrowed contact details: a forwarder’s or broker’s address, email or phone.
- A non-physical address: a P.O. box, virtual office or business service centre.
- A name mismatch: a legal name that differs from your incorporation documents, or an undeclared trading name (block 1C).
- The wrong number type: requesting a CBP-assigned number when you already hold an EIN.
- An indirect POA: one arranged through a freight forwarder rather than signed directly with the broker.
- A stale email address: CBP sends voiding notices to the email most recently submitted.
- A dormant number: over a year unused, after which it can be removed.
If your number has already been voided, CBP’s notice says questions and requests for reinstatement can go to IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy”.
A Timeline to Work Back From 30 November 2026
- Now: ask your broker for the Form 5106 data CBP holds for you, and check every field against your company records.
- October: file any corrections, complete Section 3, and make sure your POA is signed directly between you and the broker.
- October–November: line up your bond and a CTPAT-validated broker, or a US importer of record, before the EO 14411 deadline.
- Early November: leave time for CBP processing and follow-up questions.
- Ongoing: update the form whenever your name, address, contacts or ownership change, and keep the number active.
How Global Import Agent Helps
Global Import Agent helps overseas brands, including UK exporters and Amazon sellers, import into the United States compliantly. For many clients we already act as US Agent or FSVP agent, and Form 5106 accuracy now sits in the same compliance setup.
- A review of the Form 5106 data held for your business, before CBP carries out its own
- Help assembling the company information and documents Section 3 asks for
- Access to our CTPAT-validated customs broker network
- The option for us to act as your US importer of record, removing your foreign IOR exposure under EO 14411
This article is for informational purposes only and does not constitute legal advice. CBP is still implementing EO 14411, and regulations, forms and enforcement timelines may change. Always re-check CBP.gov (CBP Form 5106 and its FAQ) and the Federal Register before acting. For advice specific to your situation, consult a licensed customs broker, customs attorney or trade compliance specialist.
