From NIOP General Counsel, Olsson Frank Weeda:
Here you will find our most recent memorandum regarding the voiding importer of record numbers on September 18, 2026, when Form 5106 information is inaccurate or incomplete. Because a voided IOR number cannot be used to make entry, this initiative presents an immediate business-continuity risk for importers with outdated or third-party contact information, addresses, or deficient broker powers of attorney.
Our new alert outlines the key compliance points and practical steps importers and brokers should take now, including:
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Confirming the legal entity, physical address, email address, telephone number, and identification information currently on file with CBP.
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Ensuring that the physical address and contact details belong to and are controlled by the IOR, rather than a broker, forwarder, registered agent, or other service provider.
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Verifying that every customs broker holds a POA executed directly with the IOR.
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Establishing a documented update and monitoring process to prevent entry disruption, storage costs, and avoidable enforcement exposure.
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Evaluating potentially sensitive corrections with customs counsel where prior information may have been knowingly inaccurate or connected to broader compliance concerns.
The alert also discusses CBP’s broader implementation of Executive Order 14411 and why this Form 5106 initiative should be viewed as an early indicator of more rigorous importer-vetting requirements to come. Additional memorandum will be forthcoming.