Mark September 18 on your calendar.
Starting that day, CBP will begin immediately voiding the importer number of any company whose CBP Form 5106 information is inaccurate or incomplete. This is not a routine reminder and follows Executive Order 14411, signed in June, which directed a full review of active Importer of Record data, and CBP has confirmed the enforcement date in the Federal Register. A voided importer number means you cannot import until it is reestablished, and CBP has also flagged potential broker penalties, False Claims Act exposure, and criminal liability in cases of willful inaccuracy.
Here is what to check before the deadline:
- Your physical address on file must be your actual business location, not a registered agent, a P.O. box, or a business service center.
- Your EIN or SSN needs to match your entity exactly.
- Your email and phone number need to belong directly to your company, not an intermediary.
You have two ways to check what CBP has on file. You can review your company name and address in your ACE Portal account, which should match your 5106 record. Or you can ask our team to query your 5106 record directly and confirm what is currently on file. One thing to keep in mind: that query will not show your company’s phone number, individual contact name, or email address, so it is worth checking the ACE Portal too if you want the full picture.
If anything needs updating, complete the CBP Form 5106 and send it to compliance@medey.com.
At minimum, include your importer name, EIN, SSN, or CBP-assigned number, mailing address, physical address, email address, and phone number. The form and CBP’s FAQ are both available on CBP’s site.
Given the deadline, this is worth doing sooner rather than later. A voided number does not fix itself, and reestablishing one takes longer than confirming your information is right in the first place.