CBP Form 5106 Explained and How to Get Your Importer Number Right

CBP Form 5106, the Create/Update Importer Identity Form, is the document that creates your importer record with U.S. Customs and Border Protection. Every bond, entry, bill and refund is keyed to that record, so nothing can be filed in your name until it exists. You file it once, before your first formal entry, with your legal name, an identification number (an EIN, an SSN, or a CBP-assigned number if you have neither), your mailing and physical addresses, a phone number and an email address. A broker can submit it through ACE in minutes, and CBP typically activates a new record in about two business days.

This guide is for first-time US importers and for foreign companies that have been told they need an importer number. It walks the current form block by block, explains which number belongs in block 1B, shows how to file it and how long it takes, and covers the rule in force from September 18, 2026, under which CBP voids importer numbers whose 5106 data is wrong. What the importer of record is liable for once the record exists is a separate question, covered in what an importer of record is liable for.

What Form 5106 actually does

The form is authorized by 19 CFR 24.5 and does one job: it tells CBP who you are and how to reach you, so that an identification number can be tied to a legal entity. CBP's guidance says any party that appears on an ACE transaction, including the importer of record, the ultimate consignee and a "sold to" party, needs a record. The only common exception is a Section 321 shipment for personal use.

Two things follow. The ultimate consignee on a formal entry needs a record even when someone else is the importer of record, which surprises companies that buy DDP. And a record created years ago for a one-off shipment is still your record, stale address included.

Which number goes in block 1B

Block 1B asks for one identification number and its type. Most of the confusion around the form lives here.

One rule catches people who set up a US entity late: if you hold an EIN when you submit the form, that EIN becomes your number and no CBP-assigned number is issued, whatever you checked in 1E.

The form block by block

The current form is revision 06/26, five pages including instructions, with an estimated completion time of 45 minutes. Every required field carries a red asterisk. There are four sections, and they are not equally important.

• Section 1, name and identification number. Block 1A is the full legal name, not the trade name. 1B is the number and its type. 1C and 1D handle divisions, AKA and DBA names. 1E is where you request a CBP-assigned number and give the reason. 1G is the entity type, 1H the entries you expect in a year, 1I how the number will be used, and 1J to 1M take partnership program codes such as CTPAT.
• Section 2, address information. 2A is the mailing address with a required address type. Each street line is limited to 32 characters. If 2A is a PO box, 2B, the physical location, becomes mandatory, and 2B may never be a PO box or a business service center. It can be the owner's home. 2C phone and 2E email are required. A foreign address needs the country ISO code, and where no two-character state code exists you enter "FN".
• Section 3, company information. Business description, NAICS code, D-U-N-S number, filer code, year established, related businesses, primary bank, articles of incorporation, and up to four officers or beneficial owners. All optional, with one exception: if you chose a CBP-assigned number instead of your SSN, block 3J must carry your title, name and SSN. CBP says an empty section 3 affects how it reads risk, so on a first record it is worth filling.
• Section 4, certification. Printed name, title, signature and date, under 18 U.S.C. 1001. Electronic signatures are accepted. If a broker signs as attorney-in-fact, the power of attorney has to travel with the form or the submission is rejected.

Address type, phone and email became mandatory in the March 2019 revision. Older records were grandfathered, but the moment one is updated for any reason every current mandatory field must be supplied, which is how an address change on an old record turns into a full refile.

How to file it and how long it takes

There are three routes, and the first is almost always the right one.

• Through a licensed customs broker in ACE. A broker with ABI access creates or updates the record electronically from a signed form and a power of attorney, with the fewest format rejections. If you do not have a broker yet, what a customs broker does and costs covers how to pick one.
• By email to your assigned Center of Excellence and Expertise. The subject line must read "New 5106 Add" or "5106 Update" plus your team assignment so it routes correctly. CBP's Revenue Division procedures add the format rules that cause most rejections: one form per email, PDF or TIF under 18 MB, the current form version only, and the power of attorney attached whenever someone other than an officer signed.
• On paper at a port of entry. Ports still accept a mailed, faxed or scanned copy. It is the slowest route.

CBP's published timing is about two business days for a new record and about five business days for an update such as a name or address change. Plan around the rejections rather than the processing time: an expired form version, a legal name that does not match the IRS record for the EIN, or a missing power of attorney each send the submission back to the start.

What changed on September 18, 2026

Executive Order 14411, "Strengthening Customs Enforcement," was signed on June 3, 2026. CBP's first step under it was a Federal Register notice on August 19, 2026, "Accuracy of Importer of Record Data Submitted to CBP." From September 18, 2026, CBP voids an importer number when the information on the Form 5106 for that record is inaccurate or incomplete. Earlier in the year CBP had already deactivated a reported 4.8 million records that had filed no entry in the preceding twelve months, so the agency is working through the registry systematically rather than case by case.

Three fields decide the outcome. The physical address must be the actual location of the business or the individual, so a broker's office, a forwarder's warehouse, a registered agent, a PO box or a business service center will not do. The phone number must belong to the importer. The email address must belong to the importer, not to a broker or a third party. A voided number is invalid for every purpose, including making entry, which means cargo stops at the port with no warning beyond a written notice sent to the email on file. If that email is the broker's old inbox, the notice never reaches you.

To re-establish a voided number you email a corrected, signed form to [email protected] with the subject line "Enforcing IOR Accuracy" and wait for confirmation. An inactive record is a different case: it is reactivated with a signed form to your Center under "IOR Reactivation Request," with IRS proof such as a 147C letter or an SS-4 where CBP asks for it. A W-9 is not accepted. Your continuous customs bond is written against the same record, so a void leaves the bond pointing at nothing until the number is restored.

The mistakes that cost weeks

Almost every 5106 rejection or later void traces to one of these, and each is expensive once a container is at the terminal.

• The trade name in 1A. CBP matches the name to the IRS record for the EIN. "Summit Outdoor" on the form and "Summit Outdoor Holdings LLC" at the IRS is a mismatch. Use the legal name and put the trade name in 1C as a DBA.
• The broker's address, email or phone in section 2. This was common practice for foreign importers and it is now the fastest way to lose the number. Block 2E has to be an inbox the importer reads.
• A PO box or a virtual office in 2B. Both are named as unacceptable physical locations. A home address is fine; a mail drop is not.
• A name or address change without the bond rider. If a bond is on file, a change of name or address needs a rider with the form unless the bond is under CBP's eBond program.
• Nobody at the importer keeps a copy. Keep the signed form, the submission date and CBP's confirmation. If a void notice ever arrives, that file is what gets the number back in days instead of weeks.

Keeping the record alive

Treat the importer record as a live asset with an owner inside the company. Update it within days of a move, a rename, a change of officers or a change of legal form (a sole proprietorship becoming an LLC needs a new form, because the number changes too). Ask your broker once a year to pull the record from the ACE portal and read it back to you, and if you want to restrict who can change it, 19 CFR 24.5(f) lets you freeze the record.

Sequence matters on a first import. The record comes first, then the bond, then the broker's power of attorney, then the Importer Security Filing 24 hours before the container is loaded, covered in ISF 10+2 filing requirements. Get them in that order and the first entry is routine. If you are setting all of this up alongside your first factory order, our import and export agency team runs the registration, the bond and the broker relationship as one job, and shipping and logistics takes it from the booking onward.

For a foreign brand this is also the moment to decide who the importer of record should be at all. A non-resident record with a CBP-assigned number works, but every entry then files in your name. When Jordan walks a new client through a first US shipment, the 5106 conversation usually ends with a different structure than the one they arrived with, so it is worth a fit check with Jordan before the form goes in.