Importer of Record Rules 2026: Form 5106 Checks and the Nov. 30 Deadline

U.S. Customs and Border Protection (CBP) is checking the identity data behind every importer of record number, and a wrong detail can void it. A new executive order also sets a November 30, 2026 target for bonds, good standing and stricter vetting. Importers buying from Asia should confirm their records now.

This guide is for small and mid-sized importers, sourcing managers and brand owners who ship goods from Asian factories into the United States. It explains what changed, what CBP is reviewing and the checks to run this week. Eastern Plays wrote it for readers who handle their own customs paperwork or rely on a broker.

What Is an Importer of Record and Why Does It Matter Now?

The importer of record (IOR) is the party legally responsible for a shipment's duties, accuracy and compliance. CBP identifies that party by an IOR number, usually tied to a U.S. tax ID. The record behind that number sits on CBP Form 5106, which sets up and maintains an importer's identity.

For years this record was a formality that few people updated. A buyer would file it once, change offices twice and never tell CBP. That habit is now a risk.

An executive order signed on June 3, 2026, titled Strengthening Customs Enforcement, pushes CBP to tighten who can import. Several of its deadlines run 180 days from signing. That lands on November 30, 2026.

What Is CBP Checking on Form 5106?

CBP published a Federal Register notice on August 19, 2026, titled "Accuracy of Importer of Record Data Submitted to CBP." According to a trade-law summary from Cleo Labs, CBP began voiding IOR numbers on September 18, 2026 when it finds inaccurate or incomplete data. The summary says there is no separate notice-and-cure period.

That detail comes from a third-party reading, so confirm it with CBP or your broker. The agency's own pages for the program are on its Strengthening Customs Enforcement hub.

The six data points under review are these.

CBP also wants contact details to be current and reachable. An email that bounces counts against you. A voided number is invalid for customs purposes, which could affect goods already in transit.

Why Is the Power of Attorney the Weak Spot?

A customs power of attorney lets your broker file entries on your behalf. The rule, as the summary reports it, is that the POA must be executed directly between the customs broker and the importer of record. A POA passed through a freight forwarder, a sourcing agent or another middleman does not meet it.

This catches many small importers. A forwarder may offer to "handle everything" and collect your signature on its own forms. The broker then relies on the forwarder's paperwork, not yours.

The fix is simple. Ask your broker for a copy of the POA with your company name, signature and date. Check that it names you as the principal, not the forwarder. If it does not, sign a new one directly this week.

What Does the November 30 Target Cover?

The executive order sets out several actions that DHS must take within 180 days. The text lists these for importers of record.

An importer not in good standing cannot import or carry out import-related activities, including naming a customs broker. That is a strong consequence. Details of the tests, thresholds and timing are not final, so watch CBP notices through the winter.

How Does This Hit a Small Importer Buying From Asia?

Most small U.S. importers are already compliant in spirit. The risk is in the records. A company that moved offices, changed its email or switched brokers can have a stale file without knowing it.

Bond cost is the second pressure. A higher minimum bond means a higher premium for many buyers. Ask your surety how it plans to respond. A buyer with clean entries and steady volume should be in a stronger position than one with a thin record.

The third is cash flow. If a number is voided, shipments can stall at the port. Storage and demurrage fees then start to run. Our guide on customs user fees for FY2027 shows how small fees add up in landed cost, and port delays add far more.

What Changes for Foreign Importers of Record?

The order treats foreign importers of record more strictly. It directs DHS to bar them from filing informal entries and to require that they not rely on continuous bonds unless CBP permits. They must also be validated under the Customs Trade Partnership Against Terrorism (CTPAT) or use a CTPAT-validated, licensed broker.

The definition is broad. An entity counts as foreign if it is not organized or located in the United States, lacks U.S. controlling owners, or does not own significant U.S. real property. Some small Western brands with an overseas office and no U.S. entity may fall into the category.

The same applies to non-resident importer services that sell IOR coverage to overseas sellers. If you use one, ask for its Form 5106 status and CTPAT plan in writing.

Who Is Your Importer When the Seller Quotes Delivered Duty Paid?

Under delivered duty paid (DDP) terms, the seller promises to deliver goods with duties paid. In practice, someone still acts as importer of record. It may be the seller, a forwarder or your own company.

That detail decides who carries the compliance risk. If a third party is your importer, ask whether its Form 5106 has been reviewed. If your company is the importer, you carry the exposure even if you never touched the paperwork.

At Eastern Plays, we advise buyers to write the IOR name into every purchase order. A line such as "Importer of record: [your company]" removes guesswork. It also gives you grounds to push back when a forwarder offers to file under its own number.

How Do You Audit Your Own IOR Record in an Hour?

You can finish a basic review in one sitting. Gather your Form 5106 data, your broker's POA and your latest bond paperwork.

Then update anything that is off. If you believe a number was voided, the summary says to email the CBP IOR program office with the subject "Enforcing IOR Accuracy." Check the CBP hub for the current contact before you write.

Does the Supplier File Still Matter?

Yes. The same executive order calls for supplier documentation rules within 90 days of signing. A strong supplier file supports your entries if CBP ever asks questions. Our guide to building a supplier file for heightened import disclosures covers what to keep.

Forced-labor checks fit here too. Review your factories against the UFLPA Entity List before each season. A clean importer record and a clean supplier file protect each other.

Classification is a third piece. A wrong tariff code is a common source of penalties. Our walkthrough on how to find your HTS code and ask for a binding ruling shows when to get a ruling in writing.

What Should You Watch Between Now and Year-End?

Watch for CBP notices in the Federal Register and in its trade messages. The November 30 date is a target for the agency, not a promise that every rule will be final. Some pieces may arrive in stages.

Do not wait for final rules before you tidy your records. The Form 5106 review is already running, and a mistake is cheaper to fix now than at the port. A counterpoint is fair. Some details, such as asset thresholds, may prove lighter than feared, and many importers will be unaffected.

Your Next Step

Block one hour this week. Pull your Form 5106 data, request your POA and check your bond. Then ask your broker to confirm in writing that your IOR number is active and your records match.

Eastern Plays editors will update this guide when CBP publishes the final standards. Until then, treat accurate records as part of your landed cost.