U.S. Customs and Border Protection has set September 18 as the date it will begin voiding Importer of Record numbers when the associated Form 5106 data is inaccurate. That's two days from now. A voided IOR number is invalid for any purpose, including making entry, which means your FBA inventory could stop at the port with no warning and no cure period stated in the notice.
This isn't a new rule. CBP has always required accurate Form 5106 information. What changed on August 19 is that CBP published a Federal Register notice (91 FR 53627) making clear it intends to enforce it, comprehensively, starting September 18. If you've been relying on a freight forwarder's address, a registered agent's address, or your broker's email on file, those are specifically named as defects. The fix takes an afternoon. The shipment disruption, if you skip it, does not.
What the Form Needs to Show
CBP identifies three fields where errors are most common. The physical address must be the real location of your business or the individual acting as importer. A registered agent's address, a customs broker's address, a freight forwarder's office, a P.O. box, a business service center, or any virtual office address is not acceptable. A home office is fine, as long as it's where you genuinely operate from.
The email address must be valid and belong to the importer of record, not to a broker, forwarder, or third party who filed the form on your behalf. This field matters beyond compliance: CBP says it uses that email to notify importers when something has gone wrong. If the email on file routes to your forwarder's inbox, you'll never see the notice. The phone number carries the same requirement.
The EIN must be accurate and must match the IOR name on the entry. If your U.S. LLC is the IOR, the name and EIN need to match what's on file with the IRS. A common error for sellers who set up U.S. entities through a third-party service is submitting the agent's address alongside the LLC's EIN, which pairs an invalid address with otherwise correct identity information. Both need to be right.
What to Do Before September 18
The first step is pulling your current Form 5106 record and reading what CBP has on file, not what you believe was submitted when you first registered. Request the current record from your customs broker or through the ACE Secure Data Portal, and compare each of the four fields against what's required. Don't assume it's correct.
If your power of attorney with your customs broker was arranged through a freight forwarder rather than executed directly between you and the broker, that needs to be corrected before your next shipment. CBP requires the POA to be signed directly between the broker and the importer of record. One signed by a forwarder as intermediary doesn't satisfy the requirement, and a broker operating under a defective POA adds a second exposure on top of the Form 5106 issue.
If your IOR number does get voided, CBP says the path to reestablishment is email to IORProgram@cbp.dhs.gov with the subject line "Enforcing IOR Accuracy" and the identity documentation CBP requests. That's a workable process, but it takes time your shipments won't have if inventory is sitting at port. The faster option is to verify the record now and not find out on September 19 that there's a problem.
The Broader Import Picture for FBA Sellers
Amazon's own guidance is explicit on one point that still surprises sellers: Amazon will not act as the importer of record for your FBA inventory, for any shipment of any size or value. You or a designated third-party IOR acting on your behalf has to clear the goods. Naming Amazon as the consignee or importer gets the shipment rejected outright. That's been true for years, but the September 18 enforcement action makes the importer record itself an active compliance requirement rather than a background assumption.
With de minimis no longer covering most shipments at U.S. ports, every FBA inbound from overseas needs a formal entry: an importer number, a customs bond, and a broker POA executed directly with the IOR. If your sourcing workflow was built around de minimis thresholds and forwarder-managed customs, that setup no longer works, and the September 18 enforcement date is a good forcing function to replace it with something that does.
Our Amazon account management work often intersects with import compliance questions, particularly for brands expanding catalog or scaling FBA inventory for Q4. If you want help thinking through the importer of record structure for your business before the enforcement date, schedule a call and we can point you toward what needs to be in place.