US IOR Accuracy Rules: CBP Sets September 2026 Enforcement Date
The August 19 CBP Notice
On August 19, 2026, U.S. Customs and Border Protection published a Federal Register notice titled “Accuracy of Importer of Record Data Submitted to CBP.” The notice says CBP is taking initial steps to implement Executive Order 14411 and will use enhanced procedures to verify information for new and existing importers of record.
CBP states that, beginning September 18, 2026, it may immediately void an IOR number when the information on CBP Form 5106 is incomplete or inaccurate. A voided number cannot be used to enter merchandise into the United States. This is a U.S. customs development; it does not create an equivalent rule for Canada, the UK, the EU or Australia.
What US IOR Information Must Be Accurate
The notice identifies the importer name and physical and mailing addresses, phone number, email address and tax identifier information as data that must be accurate, complete and directly associated with the IOR. CBP specifically says a physical address cannot be a registered agent, customs broker, freight forwarder, post-office box, business service center or another party’s address.
The notice also explains that CBP Form 5106 is used to request an importer identification number for making entry or requesting services that result in a bill or refund. The exact filing process depends on the importer and filing channel, so sellers should confirm operational details with CBP or a qualified customs professional.
Customs Broker and Power of Attorney Duties
A broker may submit Form 5106 for a client, but CBP requires a valid power of attorney executed directly with the IOR. The Federal Register notice says the authorization should not be routed through a freight forwarder or another third party. Brokers must also exercise due diligence and avoid transmitting information they know or should know is false, misleading or unverified.
For a China-to-US shipping program, the IOR, broker, freight forwarder and fulfillment provider should therefore agree on who owns each data field and who is responsible for updates.
Impact on China-Based Ecommerce Sellers
A China-based seller may use a U.S. subsidiary, a marketplace arrangement, a third-party importer or another structure. The correct US IOR arrangement varies by contract, product and entry model. A seller should not assume that a freight forwarder or warehouse is automatically the importer of record.
Potential operational consequences of a voided IOR number include a blocked entry and disruption to replenishment. CBP’s notice does not publish a universal delay, fee or reestablishment timetable, so those details should be treated as not publicly confirmed.