An importer number used successfully last season may no longer be ready for the next shipment. That is the practical risk behind one of the most important U.S. customs developments for cross-border sellers in 2026.
U.S. Customs and Border Protection has started enhanced reviews of Importer of Record information. If the identity data filed on CBP Form 5106 is incomplete or inaccurate, CBP can immediately void the associated IOR number. Once voided, that number cannot be used to enter imported merchandise into the United States.
For Amazon FBA sellers, this can turn an administrative mismatch into a cargo delay after inventory has already left the factory. The safest time to check the importer record is before pickup in China.
What changed in September 2026
CBP's enhanced enforcement took effect on September 18, 2026. The agency said it is reviewing information for both new and existing importers and may void an IOR number when Form 5106 data is not complete and accurate.
The required identity details include the importer name, EIN, SSN or CBP-assigned number, mailing address, physical address when different, phone number, and email address. CBP also made clear that the contact information must belong to the importer itself.
The physical address is especially important. It must represent the importer's real physical location. CBP says it cannot be replaced by the address of a registered agent, customs broker, freight forwarder, P.O. box, business service center, or another person or company.
These requirements come directly from CBP's Federal Register notice on the accuracy of Importer of Record data.
Why this matters to Amazon FBA shipments
Many international sellers use a foreign entity, customs broker, or logistics arrangement to move inventory into the United States. The exact IOR structure depends on the transaction, but it must be established before entry and supported by accurate records.
Amazon does not become the Importer of Record simply because the destination is an FBA fulfillment center. Amazon's guidance says the seller or its provider must arrange the exporter and importer roles, and inventory arriving with customs charges due may be returned. Amazon Global Selling guidance
That means a valid FBA shipment plan cannot compensate for an invalid importer number. The cartons may be correctly labeled, the freight may arrive on schedule, and the warehouse appointment may be booked, yet the cargo can still fail to clear if the IOR record cannot be used.
FreightWaves has highlighted the operational risk: an importer may not learn that its number has been voided until cargo is already moving, potentially leaving freight waiting at a port or border crossing. FreightWaves coverage of CBP importer enforcement
Pre-shipment IOR checklist for FBA sellers
Use the following review before approving pickup or international departure.
Foreign sellers and DDP shipments need extra attention
Foreign companies can participate in U.S. importing arrangements, but their records still need accurate identity and contact information. This is where older setups can create problems.
A seller may have changed its registered name, moved offices, replaced an employee email address, changed its phone number, or switched brokers since the importer record was created. Another common risk is a legacy record that uses a service provider's contact details because those details were easier to supply at the time.
Review the IOR setup as part of every new-lane onboarding and whenever the business changes its name, address, contacts, ownership structure, or customs provider. A successful entry from months ago is useful history, but it does not prove that the current record still satisfies CBP's identity checks.
What happens if CBP voids the number
CBP says it will send written notice to the most recently submitted importer email address and, when applicable, copy the customs broker that last filed an entry for the importer. The notice should explain the basis for the action and how to request reestablishment.
The importer or a customs broker holding a valid POA can then submit the requested identity evidence and corrections. Reestablishment is a recovery process, however, not a substitute for checking the record before shipping.
If cargo is already in transit, immediately coordinate with the customs broker and freight forwarder. Ask how the issue affects the estimated entry date, port storage, demurrage, examination risk, delivery appointment, and any contingency routing. Do not assume the shipment can proceed under another importer's number without a properly structured and documented entry.
Information to send your logistics provider
Before booking a China-to-U.S. FBA shipment, provide or confirm:
- The legal name of the seller and the intended Importer of Record
- The importer number type and the party responsible for maintaining it
- The importer's physical address, mailing address, email, and phone number
- The customs broker's name and current POA status
- Product descriptions, HTS classifications, country of origin, and declared values
- Commercial invoice and packing-list details
- Amazon shipment IDs, warehouse codes, and delivery requirements
- A contact who can respond quickly if CBP requests identity or product information
Clear importer records do more than satisfy a form. They protect the handoff between international transport, customs clearance, final-mile delivery, and Amazon receiving. For FBA sellers planning peak-season inventory, checking the IOR before pickup is now as important as checking carton labels and warehouse assignments.
Confirm the importer, cargo details, and delivery plan before your next China-to-FBA shipment with DartFBA.
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