If your supplier is the importer of record, September 18 is your problem

What happens on September 18, 2026?

CBP will begin voiding importer of record numbers where the information on CBP Form 5106 is inaccurate or incomplete. A voided number cannot be used for any purpose, including making entry — which means cargo stops at the port. CBP published the notice in the Federal Register on August 19, 2026. There is no cure period described and no warning before the action.

That's the short answer. Here's why it lands harder on buyers importing from China than most of them realise.

The part nobody is telling DDP buyers

Plenty of importers buying from Chinese suppliers on DDP terms have never asked a simple question: who is the importer of record on my entries?

Under DDP, the seller handles delivery through customs. In practice that often means the Chinese supplier, or a forwarder acting for them, is the party on record — and the contact details on that record are the forwarder's, not anyone's who actually exists in the United States.

CBP has now said plainly what will not pass:

• The physical address must be the actual location of the business. A registered agent, a customs broker, a freight forwarder, a P.O. box, a business service centre, or anyone else's address is a defect.
• The email address must be valid and belong to the importer of record. A broker's or forwarder's address in that field no longer passes.
• The phone number must be valid and belong to the importer of record.

Read that against a typical DDP arrangement from Guangzhou or Yiwu and the exposure is obvious. The record is often built entirely out of intermediary contact details, because there was never a US premises to list.

The notification trap

CBP says it will send the voiding notice to the email address the importer of record most recently submitted.

Sit with that for a second. The records most likely to have a wrong email are exactly the records most likely to be voided — and the notice goes to the wrong email. The first sign of trouble is a broker who cannot file an entry, with your container sitting at the port and demurrage running.

Reestablishment happens afterwards, by email to CBP, on a timeline that has not been published.

How big is this sweep?

Larger than a spot check. Earlier this year CBP deactivated roughly 4.8 million importer of record accounts that had not filed an entry in the preceding year. The agency has said it is comprehensively reviewing Form 5106 data across the register. This is systematic, not case by case.

It also isn't happening in isolation. On June 3, 2026 the President signed Executive Order 14411, Strengthening Customs Enforcement. Among other things it directs tighter importer eligibility rules, minimum domestic asset and bonding requirements, a "good standing" threshold for import privileges, and a penalty mitigation floor of not less than 50% with no mitigation at all for repeat offenders. The Order also restricts foreign importers of record: no informal entry, no reliance on a continuous bond without CBP approval, and a CTPAT validation requirement for formal entry.

The Form 5106 notice is the first concrete implementation step. It won't be the last.

What to check this week

This is your customs broker's and your trade counsel's territory, and you should use them. What you're checking is short:

1. Ask your broker who the importer of record is on your recent entries. If you buy DDP and have never asked, ask today.
2. Pull your actual Form 5106 record — through your broker or the ACE portal. Not what you believe was filed. What CBP has now.
3. Test the address field. If an officer visited that address, would they find your business operating there? If the answer involves a mail service, an agent, a lawyer, a broker, a forwarder, or someone else's warehouse, it needs to change.
4. Put a monitored email address you control in the record. It's the channel CBP will use to tell you something has gone wrong.
5. If a foreign entity is your importer of record, treat it as a structural question, not a data-entry one. That's a conversation with customs counsel, and it should happen before the deadline rather than after.

One caution worth stating plainly: if a previous certification was knowingly inaccurate, correcting it now may itself carry consequences. That sequencing is a legal question. Speak to customs counsel before filing, not after.

Where this actually points

Step back from the form and look at the direction of travel. CBP has spent years collecting information. It is now enforcing against the information it collected — and every new requirement points the same way: who really is your importer, who really made the goods, and can you show it.

Executive Order 14411 also directs that importers may be required to submit documentation the foreign exporter filed with its own customs administration before shipping. That paperwork doesn't sit in an office in New Jersey. It sits in a supplier's office in China, and it is produced by someone who can go and ask for it.

The importer-of-record question is answered in the United States. The evidence question is answered where your goods are made.

Sources: CBP Federal Register notice, August 19, 2026; Executive Order 14411, June 3, 2026. Accurate as of August 2026 — confirm current requirements with your customs broker or counsel.