Numerous CTPAT-certified importers have received letters from U.S. Customs and Border Protection saying their importer of record (IOR) numbers may be voided. The concern is the accuracy of the information they previously submitted on CBP Form 5106. According to a customs brokerage citing an alert from the NCBFAA Customs Committee, the affected numbers may become invalid for entries filed from 12:01 a.m. ET on November 18, 2026. CBP would void them unless the concerns are addressed.
This follows a Federal Register notice from August 19, under which CBP began voiding IOR numbers on September 18 when the information on Form 5106 is inaccurate or incomplete. A voided number is invalid for every purpose, including making entry, so unresolved issues could stop shipments from clearing. The notice did not describe a request for information, a cure period or a hearing before voiding.
What to check
The fields to verify are the importer name, identification number (EIN, SSN or CBP-assigned number), mailing and physical addresses, email address, phone number and broker power of attorney. The notice sets rules for three of them. The physical address must be the actual location of the business, not a registered agent, customs broker, freight forwarder, P.O. box or business service center. The email address and phone number must belong to the importer, not to a broker or other third party.
The email matters most. CBP sends the voiding notice to the email address most recently submitted, and copies the customs broker that last filed an entry for the importer when it can. If that address belongs to a broker, or is out of date, the importer may learn about the voiding only when cargo stops.
What to do before November 18
Review and correct the Form 5106 information in the ACE Secure Data Portal. Confirm in the CTPAT Portal that the IOR number is active and matches the ACE record. Replace any broker, forwarder or service-provider contact details with the importer’s own. Work with your customs broker to review the records before the deadline.
If a number is voided, CBP sends written notice explaining how to request reinstatement. The importer, or a broker with a valid power of attorney, can email IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy.” CBP has not published a timeline for reinstatement.
The letters were reported by a customs brokerage, citing an NCBFAA alert, and the article does not say what criteria decided who received one. If you have not seen a letter, that does not mean your record is clean. Importers that have not reviewed their Form 5106 data since August should do it now.
If you want help going through your IOR record, reach out to our team. More trade compliance updates at www.shiptech.com/blog