Enhanced Customs Enforcement on Validating Importer of Record
For: Shippers, Receivers
Shipping: Packages
Effective September 18, 2026
What you need to know
On June 3, 2026, President Trump signed Executive Order 14411, Strengthening Customs Enforcement, directing US Customs and Border Protection (CBP) to strengthen importer accountability and customs enforcement.
These measures are intended to ensure that CBP can accurately identify and verify the businesses and individuals importing goods into the United States, helping to prevent undervaluation, misclassification, duty evasion, and the use of fraudulent or fictitious importer identities. By requiring accurate and verifiable importer information, CBP aims to strengthen compliance with US trade laws and improve its ability to identify and address high-risk import activities.
Effective September 18, 2026, CBP began enhanced enforcement of importer identification requirements, including::
- Verifying the accuracy of CBP information on record for new and existing Importers of Record (IORs).
- Requiring importer information to be accurate, complete, and current.
- Immediately voiding importer numbers when information is inaccurate or incomplete, potentially preventing customs clearance.
What this means for importers
Importers are responsible for maintaining accurate information with CBP, including:
- Legal business name and tax identification number.
- Actual physical business location, not a PO Box, broker, freight forwarder, registered agent, or other third-party address.
- Valid telephone number and email address directly associated with the importer.
Importers must respond promptly to CBP requests to verify or correct their information.
If CBP voids your IOR number, you will need to follow the steps as outlined in the CBP FAQ page linked below. Importers are responsible for working directly with CBP to resolve discrepancies and request reactivation.
Enhanced DHL Express onboarding requirements:
In response to CBP's enhanced enforcement measures, DHL Express USA is strengthening its due diligence procedures for customers requesting to act as the IOR.
Customers will be required to provide:
- A valid Power of Attorney (POA)
- Supporting documentation verifying business identity and tax identification number
- Government-issued identification of the authorized POA signatory
- Documentation verifying the importer's actual physical business location
- Accurate and complete Form 5106 information
DHL may also request additional information when establishing new entities in CBP's system.
DHL Express will continue providing updates as additional requirements are implemented.
Definitions:
Importer of Record (IOR): The party legally responsible for customs entry and compliance with applicable US import requirements.
CBP Form 5106: The Create/Update Importer Identity Form, used to establish or update identification and contact information for importers and ultimate consignees.
Importer create or update Identity Form (CBP Form 5106) FAQs