The reinforced Importer of Record validation procedures started on 18 September 2026. Since then, CBP can immediately void an importer number with incorrect or incomplete information.
Shipping from Brazil to the US: new CBP customs guidance on the Importer of Record
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If you are shipping from Brazil to the US, check the receiver's and the importer's details before the parcel leaves. Since 18 September 2026, U.S. Customs and Border Protection (CBP) has tightened how it validates Importer of Record (IOR) information. Wrong or outdated data can lead to document requests, clearance delays and even a cancelled importer number.
The update is a reminder that importer and receiver data must be correct and current. For a Brazilian sender, that means the shipment is prepared in Brazil but judged in the US: a wrong phone number, a forwarder's email in place of the customer's, or an invoice that does not match the electronic data all turn into correction requests after the box has already landed.
What changed at US customs in September 2026?
From 18 September 2026, CBP, the customs authority of the United States, reinforced its enforcement and validation procedures for information related to the Importer of Record (IOR).
The update underlines a basic rule for anyone importing goods into the United States: the data presented to customs must be correct, complete and up to date.
Incorrect or outdated information can trigger requests for additional documents and delays in customs clearance. For the Importer of Record, inconsistencies can also lead to the cancellation of the importer number in CBP's system.
CBP announced the measure in a notice published in the Federal Register on 19 August 2026, as one of the first steps to implement Executive Order 14411 of 3 June 2026 on strengthening customs enforcement. The review covers both new and existing importers (Source: CBP, Federal Register, August 2026).
What does this mean for shipments to the US from Brazil?
When you prepare a shipment, check the information about the goods. Then give the same attention to the details of the person or company receiving them in the United States.
A few points matter most:
- Complete and current contact details: the receiver's phone number, email and physical address must be entered correctly.
- Consistency across the shipment data: the details on the commercial invoice must match the information transmitted electronically when the shipment is created.
- The receiver's real details: the receiver's contact information must not be replaced with the details of the shipper, the customs broker or any other third party.
These checks make communication easier during customs clearance and reduce the need for corrections once the shipment reaches the United States.
Invoice consistency is the step that slips most often, especially when a Brazilian small business copies details from an old order. Our commercial invoice guide is worth a quick read before your next dispatch.
Which importer details does CBP check?
CBP checks whether each detail in the importer's record exists and belongs to the importer. That record is CBP Form 5106, the form that creates the IOR number, and it asks for the importer's name, US tax identification number, mailing address, physical address, phone number and email.
The table sums up what CBP requires for each field and the mistake that most often causes trouble:
Detail | What CBP requires | Common mistake |
Physical address | The actual location of the business or person | P.O. box, customs broker, freight forwarder or business service center address |
Valid and owned by the importer | The shipper's, broker's or another third party's email | |
Phone | Valid and owned by the importer | The phone number of whoever booked the shipment |
Tax ID | Correct and owned by the importer | An outdated number after a company change |
Broker's power of attorney | Signed directly with the importer | Executed through a forwarder or other third party |
Source: CBP, "Accuracy of Importer of Record Data Submitted to CBP", Federal Register, 19 August 2026.
Can DHL Express contact the receiver?
Yes. During customs clearance, DHL Express U.S. may contact the receiver directly if additional information or documents are needed.
This contact may also happen when identity needs to be validated or when details related to the import process must be confirmed.
So, besides entering correct data at the time of shipping, the receiver should be ready to respond to the requests needed for clearance.
A simple habit helps: when you close a sale, tell your US customer they may hear from DHL Express U.S. and that a quick reply keeps the parcel moving. One line in the order confirmation is enough.
What is the Importer of Record (IOR)?
The Importer of Record (IOR) is the party registered as responsible for importing the goods into the United States and for meeting the applicable CBP requirements.
If you are the IOR, keeping your registration details correct and current matters even more under the reinforced validation procedures.
If any company or importer information has changed, the corresponding records must be updated to avoid discrepancies during customs clearance.
The IOR is also liable for the duties owed at entry. That is why CBP cares so much about identifying it, and why the same role comes up in the discussion of US Section 301 tariffs on Brazilian goods: the importer is the one who pays.
What happens if the importer number is voided?
If CBP finds that the record is incomplete or inaccurate, the IOR number is voided immediately and becomes invalid for any purpose, including entering goods into the United States. CBP sends a written notice to the email address the importer most recently submitted, explaining the reason and how to request reinstatement (Source: CBP, Federal Register, August 2026).
Note the detail: the notice goes to the email on file. If that email belongs to a third party or is out of date, the importer may not even know the number has been voided. Reinstatement requires documents proving the importer's identity and is handled directly with CBP.
I already have a power of attorney on file with DHL Express U.S. Do I need to do anything?
Customers who already have a Power of Attorney (POA) registered with DHL Express U.S. do not need to take any further action at this time, provided the registered information remains correct and current.
If any importer details have changed, make sure that information is updated as well.
For new processes, additional documents may be requested for validation depending on the situation.
How can you avoid clearance delays?
Before shipping from Brazil to the US, check:
- That the receiver's name, physical address, phone number and email are correct.
- That the commercial invoice matches the shipment's electronic data.
- That you used the receiver's real contact details, not the shipper's or a third party's.
- That the Importer of Record information is up to date with CBP, where applicable.
- That the receiver knows DHL Express U.S. may contact them for additional information or documents.
Correct data from the start reduces the risk of delays and makes customs clearance more efficient.
For the rest of the preparation (packing, restrictions and Brazilian-side paperwork), our guide to shipping from Brazil to the US and the list of essential import and export documents complete the checklist.
What about express shipments arriving in Brazil?
The same logic applies in the opposite direction: incomplete data at origin becomes a shipment on hold at destination. Since 1 October 2026, Siscomex Remessa checks two pieces of information before it registers the Declaração de Importação de Remessa (DIR), the import declaration used for express shipments entering Brazil:
Information | Purpose | Requirement | Who provides it |
NCM | Tariff classification of the goods | At least the first 6 digits of a valid code | Shipper, on the invoice and the air waybill (AWB) |
cClassTrib | Tax classification linked to Brazil's consumption tax reform | Valid 6-digit code | Courier company, based on the NCM received |
If the data does not meet these rules, the transmission is rejected and the DIR is not registered. The shipment then waits for the information to be corrected or completed, which can extend the release time and, depending on the case, lead to a return to origin.
If your company also receives goods from abroad by courier, ask your supplier to:
- provide the NCM that actually matches the product, not a generic code chosen just to get the shipment through;
- describe the goods with brand, model, quantity, unit of measure, value and country of origin;
- avoid descriptions such as "parts", "samples", "gift", "goods" or "merchandise" without identifying the item.
The NCM does not replace a detailed description, and responsibility for the goods data lies with the shipper. DHL Express transmits the information to Receita Federal, the Brazilian tax and customs authority, assigns the cClassTrib, monitors any rejections and corrects inconsistent or incomplete information, but it does not decide the commercial classification of the product on the shipper's behalf (Source: DHL Express, FAQs on the new NCM requirements, 1 October 2026).
If you are unsure about a classification, the official references are Siscomex Import Notice No. 101/2026 (Comunicado Siscomex Importação nº 101/2026) and the NCM lookup on the Portal Único Siscomex, both in Portuguese.
Frequently asked questions about the new US customs guidance
No. The receiver's contact details must not be replaced with those of the shipper, the customs broker or any other third party. Use the real phone number and email of whoever receives the shipment in the United States.
No. CBP requires the importer's physical address to be the actual location of the business or person. P.O. boxes and the addresses of customs brokers, freight forwarders or business service centers are not accepted.
No, as long as the registered information remains correct and current. If any importer details have changed, they must be updated, and additional documents may be requested for new processes.
CBP sends a written notice to the email address the importer most recently submitted, with the reason and instructions to request reinstatement. That is why the email on file must belong to the importer and be actively monitored.
Not necessarily. Siscomex Remessa requires at least the first 6 digits of a valid NCM code. When the full classification is available, DHL Express recommends keeping it in the shipment's commercial data.
No. The check applies to shipments subject to a DIR in Siscomex Remessa, including those sent by companies. Nothing changes for formal shipments to Brazil.
Sources
- CBP: Accuracy of Importer of Record Data Submitted to CBP, Federal Register, 19 August 2026
- CBP: Importer Create/Update Identity Form (CBP Form 5106) FAQ
- DHL Express: FAQs, "Novas exigências de NCM para Remessas Expressas ao Brasil" (new NCM requirements for express shipments to Brazil), updated 1 October 2026
- Siscomex: NCM lookup on the Portal Único Siscomex
Shipping to the United States?
Review your shipment details before sending and keep the receiver's and importer's information up to date.
Important: customs requirements may vary depending on the characteristics of the shipment and the import process. Additional documents or information may be requested during clearance.
If shipping from Brazil to the US is part of your routine, open a DHL Express business account to ship as a company and track every parcel through to delivery.
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