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CBP Can Void Your Importer Number After Sep 18 — What Changed
CBP Can Void Your Importer Number After Sep 18 — What Changed
Starting September 18, 2026, U.S. Customs and Border Protection can immediately void an Importer of Record number if the Form 5106 data on file is wrong — including a physical address that is not the importer's real location.
If you import into the United States under your own Importer of Record (IOR) number, treat September 18, 2026 as a hard date. CBP's Federal Register notice (FR Doc. 2026-16911) says enhanced enforcement begins that day. If CBP finds incomplete or inaccurate information on your CBP Form 5106, it can immediately void the IOR number. A voided number is invalid for entry. Goods can sit. Bills and refunds can stall. Brokers cannot magically fix a dead number at the last minute.
This is not a vague "be accurate someday" memo. CBP republished the same notice in Customs Bulletin Vol. 60, No. 26 (September 2, 2026). The bulletin and the Federal Register text line up: accuracy review is live, voiding starts September 18, and reestablishment questions go to a specific CBP mailbox.
A Monroe-area seller walked in last week with a broker email open on their phone. The broker was asking for a street address that matches the business — not a mail drop, not the freight forwarder's suite, not a friend's warehouse. The seller had been using a mailing address that worked for packages. That is a different problem from Form 5106. Package receiving and importer identity are not the same thing. Confusing them is exactly how people get caught when CBP starts voiding numbers.
What Changed on September 18, 2026
CBP is implementing part of Executive Order 14411, "Strengthening Customs Enforcement." The Federal Register notice is the public heads-up.
Here is the practical summary for small importers in Monroe, Sultan, Gold Bar, Snohomish, Duvall, and Granite Falls:
- CBP is reviewing Form 5106 data already on file — not only new applications.
- Inaccurate or incomplete data can trigger immediate voiding of the IOR number starting September 18, 2026.
- Contact information must belong to the IOR — email and phone cannot be swapped in from a broker, forwarder, or friend.
- Physical location address has a short, hard list of what it cannot be (details below).
- Customs brokers must use a Power of Attorney executed directly with the IOR, not through a freight forwarder or other third party.
Voiding is not a warning letter that keeps your number alive while you "look into it." The notice says CBP will void the number, make it invalid for any purpose including entry, and send written notice to the email address most recently on file. If a broker last filed entry for you, CBP may copy that broker too.
Form 5106 in Plain English
CBP Form 5106 is the Create/Update Importer Identity Form. Under 19 CFR 24.5, it is how you create or update the identity record CBP uses for your importer number.
Per the Federal Register notice, required data elements include:
- Importer name
- IRS EIN, SSN, or CBP-assigned number
- Mailing address
- Physical location address if different from mailing
- Phone number
- Email address
Optional blocks cover company details, business structure, beneficial ownership, and officers. Optional does not mean "ignore forever" if those fields are how CBP later verifies who you are. It means the notice's hard enforcement pitch is aimed first at identity accuracy — especially addresses and contact points that belong to the IOR.
You (or a licensed customs broker with a valid Power of Attorney) submit the form through the Automated Broker Interface or by email to the right Center of Excellence and Expertise. Most Monroe small importers never see the ABI screen. Your broker does. That does not remove your duty to keep the record true.
The Address Rule People Mix Up
This is where Monroe importers get tripped — and where rumor outruns the official text.
What the Federal Register says
In Section II of FR Doc. 2026-16911, CBP states that the physical address for the IOR must be the actual physical location of the business or individual. It cannot be:
- a registered agent
- a customs broker
- a freight forwarder
- a P.O. box
- a business service center
- an address of another person or entity
A footnote points back to the Form 5106 instructions: the physical address must be associated with the business or individual, and the principal's home address can qualify as the business-associated address.
What the Form 5106 instructions say
The June 2026 Form 5106 PDF instructions draw a bright line between mailing and physical location:
- Mailing address (2A): may be a post office box. If mailing is a P.O. Box, you must provide a second address (physical location) in 2B.
- Physical location address (2B): "Provide the address that is associated with the business or the individual. This address cannot be a P.O. Box, Business Service Center, etc. The address associated with the business can be the principal's home address."
So: a P.O. Box can be fine for mail. It is not fine as the physical location on Form 5106. That distinction already lived in the form instructions. The September 18 change is that CBP says it will void numbers when the on-file data fails accuracy checks — including that physical-location rule.
About "CMRA" and private mailbox language
The Federal Register notice and the Form 5106 instructions do not use the word "CMRA" (Commercial Mail Receiving Agency). They do ban a P.O. box and a business service center for the physical location address, and they ban using another person's or entity's address.
If someone tells you "CMRAs are newly outlawed on September 18," that is not how the notice is written. What is written: physical location must be the importer's actual location, not a P.O. box, not a business service center, not a broker/forwarder/agent address. Private mailbox and CMRA-style storefront addresses are commonly classified as business service centers for identity paperwork. Treat them as off-limits for Form 5106 physical location, because that is how the "business service center" rule reads in practice — and cite the official words above, not blog folklore.
Do not use a private mailbox, CMRA suite, or mail-store street address as your Importer of Record physical location on Form 5106. That is the opposite of what CBP is enforcing. A rented mailbox can still be useful for receiving packages and mail. It is not a substitute for the importer's real physical location on identity paperwork.
Email, Phone, and Broker Rules That Also Void Numbers
Address is not the only landmine.
Email: must be valid and belong to the IOR. Brokers and third parties may not put their own email in place of the importer's.
Phone: must be valid and belong to the IOR. Same rule — no broker phone standing in for yours.
Broker Power of Attorney: if a broker files Form 5106 for you, the POA must be executed directly with the IOR, not via a freight forwarder or other middle party (19 CFR 111.36(c)(3), as cited in the notice).
The notice also reminds certifying parties about 18 U.S.C. 1001 (false statements) and points to False Claims Act risk when inaccurate IOR data is material to money owed to CBP. Brokers who transmit information they know or should know is false or misleading face separate broker-penalty exposure under 19 U.S.C. 1641.
Translation for a Monroe side-hustle importer: if your broker "just put something that clears," and that something is not your real contact data or location, both of you can own the fallout.
What Happens If Your IOR Number Is Voided
Per Section III of the notice:
- CBP voids the IOR number immediately (starting September 18, 2026) when it finds inaccurate or incomplete Form 5106 data.
- The number becomes invalid for any purpose, including entering merchandise.
- CBP emails a written notice to the email most recently on file for the IOR.
- CBP may copy the customs broker that last filed entry for that IOR.
- The notice explains how to request reestablishment and what identity corroboration CBP needs.
Questions about the enforcement effort — and requests to reestablish a voided number — go to:
IORProgram@cbp.dhs.gov
Subject line: Enforcing IOR Accuracy
That mailbox and subject line are in the Federal Register ADDRESSES block and the Customs Bulletin reprint. Use them exactly. Do not invent a different subject line and hope it routes.
Reestablishment is not automatic. Expect to prove who you are with accurate Form 5106 data. If your prior record used a P.O. box or business service center as physical location, fix that before you ask CBP to turn the number back on.
Who in the Monroe Area Should Care Most
This hits people who actually import under their own number — not every family shipping a gift abroad.
Online sellers and product businesses bringing inventory into the U.S. under their own IOR.
Home-based importers along the US-2 corridor who used a "cleaner looking" mailing address for paperwork because the home address felt too personal. CBP explicitly allows a principal's home address as the business-associated physical address. Hiding behind a non-physical location is the problem.
Importers who let a forwarder or broker "handle identity." The notice says contact data and physical location must belong to the IOR, and POAs must run directly to the IOR.
Anyone who has not updated Form 5106 after a move, name change, or phone/email change. Stale data is inaccurate data.
If you only ship outbound gifts and documents from Monroe and never act as Importer of Record on inbound commercial entries, this notice is still worth knowing — but your day-to-day risk is different. Your risk is bad customs declarations on packages you send. That is covered in our customs forms guide and package held at customs posts. Form 5106 is the inbound identity record.
What to Do Before September 18 (Checklist)
Do this with your broker, or yourself if you self-file:
- Pull your current importer identity record / last Form 5106 submission
- Confirm legal name matches how you import
- Confirm EIN / SSN / CBP-assigned number is correct and belongs to you
- Confirm mailing address is where you actually receive mail (P.O. Box allowed for mailing)
- Confirm physical location is your real business or personal location — not a P.O. Box, not a business service center, not a broker/forwarder/agent address, not someone else's site
- If mailing is a P.O. Box, make sure physical location (2B) is filled in
- Confirm phone and email are yours and monitored
- If a broker files for you, confirm the Power of Attorney is executed directly with you
- File updates on Form 5106 before September 18 if anything is wrong
- Save the CBP contact: IORProgram@cbp.dhs.gov / subject "Enforcing IOR Accuracy"
| Field | Allowed | Not allowed for physical location |
|---|---|---|
| Mailing address | Street or P.O. Box (per form instructions) | N/A — mailing rules differ |
| Physical location | Actual location of business or individual; principal home OK | P.O. Box; business service center; registered agent; broker; freight forwarder; another person's/entity's address |
| Email / phone | Belong directly to the IOR | Broker or third-party stand-ins |
| Broker filing | Valid POA executed directly with IOR | POA routed only through a forwarder/third party |
Sources for the table: FR Doc. 2026-16911 and CBP Form 5106 instructions (06/26).
How This Intersects With International Shipping From Monroe
Two paperwork worlds share the word "customs" and confuse people at the counter.
Outbound shipping paperwork (CN22, CP72, commercial invoice) is about the package you send from Monroe to another country. Wrong descriptions and values cause holds abroad. See Customs Forms Explained and US tariffs / package impact.
Importer of Record / Form 5106 is about who you are when goods enter the United States under your number. Wrong identity data can void the number itself after September 18.
If you buy abroad and import commercially, you need both worlds clean: accurate IOR identity and accurate entry/shipping documents. If you only send personal packages outbound, Form 5106 may not be your form — but your commercial invoice still needs honest values and descriptions.
At The Mail Station Monroe, we help with the outbound side every day: carrier choice (FedEx, DHL, USPS), customs form help at the counter, and packing for international transit. We are a shipping and mailbox retail counter — not a customs broker and not your Form 5106 filer. For IOR identity questions, work with your licensed customs broker and CBP's IOR program mailbox. For packages leaving Monroe, walk in with the item, real value, and recipient details, and we will help you ship it without guessing the paperwork.
Frequently Asked Questions
Does CBP really void numbers starting September 18, 2026?
Yes. The Federal Register notice and the Customs Bulletin Vol. 60 No. 26 both state that enhanced enforcement, including immediate voiding for inaccurate Form 5106 information, commences on September 18, 2026.
Can my physical location be a P.O. Box?
No. Form 5106 instructions say the physical location address cannot be a P.O. Box or Business Service Center. The Federal Register notice repeats that a physical address cannot be a P.O. box or business service center. A P.O. Box may still be used as a mailing address if you also provide a real physical location.
Did CBP say "CMRAs are banned"?
Not in those words. Official text bans P.O. boxes and business service centers (among other non-physical stand-ins) for the physical location field. Do not invent a CMRA quote. Do not use a private mailbox or mail-center address as Form 5106 physical location.
What if my number already got voided?
Email IORProgram@cbp.dhs.gov with subject Enforcing IOR Accuracy, follow the written notice CBP sent to your on-file email, and be ready to corroborate identity with accurate Form 5106 data. The IOR or a broker with a valid POA may contact that mailbox about a voided number.
Can The Mail Station fix my Form 5106?
No. We are not a licensed customs broker and we do not file Form 5106. We can help you understand how shipping paperwork differs from importer identity paperwork, and we can help you ship outbound international packages from Monroe correctly.
Shipping Outbound From Monroe While You Sort IOR Paperwork?
If you need to send a package internationally while your broker updates Form 5106, bring the item and honest contents/value to the counter. We handle FedEx, DHL, and USPS international drop-off and form help for outbound shipments.
The Mail Station
19916 Old Owen Road, Monroe, WA 98272
(360) 805-9250
Mon-Fri 9 AM-6 PM · Sat 9 AM-4 PM · 24/7 mailbox access
Contact us · International shipping
Related Reading
Package Held at Customs? Here's What Actually Helps — inbound holds are paperwork problems; different from a voided IOR number, but the same "accuracy first" habit.
Customs Forms Explained: CN22, CN23 & Commercial Invoice — outbound declaration forms for packages leaving Monroe.
2025-26 US Tariffs: What They Mean for Your Packages — duty and tariff context for importers and shippers.
Shipping to the EU Just Changed: New Duties & Paperwork Rules — outbound EU rule changes that pair with stricter U.S. identity enforcement.
Shipping Documents Overseas? Don't Pay Package Rates — when you are mailing papers, not importing goods under an IOR number.
DHL vs FedEx International Shipping: Which Is Faster? — carrier choice for outbound international from Monroe.
How to Ship to Canada from Monroe, WA — nearest international destination paperwork.
How to Ship to Mexico: Options That Actually Arrive — cross-border outbound tips.
Why Your Package Clears Canada but Stalls in Mexico — clearance differences that still hinge on accurate paperwork.
What Can't You Ship via USPS, FedEx & UPS? (2026 Guide) — restricted items that cause holds even when identity is clean.
Explore Services
Written by the team at The Mail Station Monroe — helping Monroe, Sultan, Gold Bar, Snohomish, Duvall, and Granite Falls residents with international shipping paperwork since 1982. We are not a customs broker; Form 5106 and IOR reestablishment must go through CBP and your licensed broker.
Need Professional Mail & Shipping Services?
The Mail Station has been serving Monroe, Sultan, and Gold Bar since 1982. We offer secure mailbox rentals, professional shipping services, and expert advice.
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