CBP may void inaccurate importer of record numbers, widen broker vetting

CBP can void inaccurate importer of record numbers from 30 days after publication of its notice. CTPAT-validated brokers will have to vet foreign clients.

By Procupy News DeskPublished 6 Nov 2026, 3:16 PM IST3 min readSource: The Loadstar

In 60 words

CBP has published a notice on importer of record data accuracy. From 30 days after publication it may void a number and take other enforcement action. CTPAT-validated brokers will have to vet foreign importer clients more closely. CargoTrans says US buyers on DDP terms can face penalties, seizures and refused entries even when not the importer of record.

Key points

CBP may void an importer of record number and take other enforcement action from 30 days after publication of its notice¹.
CBP has notified CTPAT partners that CTPAT-validated brokers will have to vet foreign importer clients more closely¹.
US buyers on DDP terms could face penalties, seizures and refused entries even when not the importer of record, CargoTrans said².
Seatrade Maritime reported that CBP linked the restrictions to about $1 billion in unpaid duties³.

US Customs and Border Protection will be able to void an importer of record number if the details behind it are wrong. It is also widening what CTPAT-validated customs brokers must check on foreign clients¹. The measures sit under Executive Order 14411, which CBP calls the "Strengthening Customs Enforcement" order¹.

CBP said it has published a notice on the accuracy of importer of record data, though its page does not give the publication date. From 30 days after publication, the agency may "immediately void an associated IOR number and take other appropriate enforcement actions" when information on CBP Form 5106 is inaccurate or incomplete¹.

CBP also alerted trade partners about foreign clients. It notified CTPAT partners that CTPAT-validated brokers will have to "conduct additional vetting on their foreign importer clients". That puts foreign importers on the same footing as US ones¹.

Seatrade Maritime reported on 6 November that CBP had introduced sweeping new import restrictions. It said the agency put US customs brokers on the hook for import fraud and cited about $1 billion in unpaid duty as the catalyst³. CBP's enforcement page does not give that figure¹.

DDP leaves US buyers exposed

CargoTrans executives warned that US buyers using delivered duty paid (DDP) terms could face penalties, seizures and refused entries. That applies even when the buyer is not named as the importer of record². Under DDP, the seller clears customs and pays the duty. Rennie Alston is the company's director of trade compliance. He said: "If you are the US consignee, if you are the US order party, if you are the instigator to the transaction, then you have culpability"².

CargoTrans said CBP was increasingly looking into whether companies used DDP arrangements to avoid tariffs. It said the agency was looking closely at foreign sellers and platform intermediaries acting as non-resident importers of record². Some US buyers had reported shipments refused entry, seized or ordered for re-export, including cases with incorrect importer information².

CBP's page does not say whether the broker vetting also covers non-resident importers of record¹. A separate CBP proposal on low-value shipments would require bonds for all informal entries¹.

What to do now

Importers should check the name, address and identity details on their Form 5106 record. CBP can void the number if the information is wrong¹. They should also ask their broker what new documents it needs before filing¹.

For DDP shipments, CargoTrans recommended demanding access to customs declarations, transaction documents and import data. It said buyers could not claim ignorance of what had been declared for them². It suggested some companies may switch to delivered at place (DAP) terms to keep control of the entry².

CBP sends requests for information, known as CF28s. Alston said importers should check records across procurement, finance, legal, compliance and logistics before replying. He warned against rushing to meet the standard 20-day deadline without those checks². CargoTrans also said CBP is issuing notices of action without a CF28 first. Importers who disagree may need to pay the duty and then challenge it through the protest process, it said².

What comes next

CBP is taking comments on two related proposals. One is an advance notice on supply chain visibility, with a 90-day comment period ending on 1 December 2026. The other would require bonds for all informal entries, with a 60-day comment period ending on 7 December 2026¹.

What this means for procurement teams

Importers now carry two paperwork risks at once: whether their own customs record is correct, and how whoever files for them behaves¹. CBP can void an importer of record number when Form 5106 details are wrong. It can take other enforcement action at the same time¹. Basic company data is now a live compliance item, not an onboarding formality.

Buyers who leave clearance to a DDP seller should not assume they are shielded. CargoTrans said US buyers may face penalties linked to their import bonds. It said some buyers had reported shipments being refused, seized or ordered for re-export². Contracts should name who is importer of record, require the seller to share declarations and entry data, and set out who pays if duty is reassessed².

Three steps follow. Audit Form 5106 details for every entity that imports, and ask brokers what evidence they now need from foreign clients¹. Decide whether DDP still fits each lane, or whether delivered at place terms give better control². Brief finance on the cash needed if a notice of action has to be paid before a protest, and consider how you would file if a number is voided^2, 1.

Sources

1.U.S. Customs and Border Protection, Strengthening Customs Enforcement. Accessed 6 November 2026.
2.The Loadstar, US importers should reconsider farming out customs paperwork, warns CargoTrans, 5 November 2026. Accessed 6 November 2026.
3.Seatrade Maritime News, CBP rule puts US customs brokers on the hook for import fraud, 6 November 2026. Accessed 6 November 2026.

How this story was made: the Procupy News Desk researched and wrote it with AI tools, working only from the sources listed above. Automated checks confirmed that every number and quote appears in those sources, and a separate AI fact-check compared the story with them before publication. Read our editorial policy. Spotted a mistake? Tell us and we will fix it.