US Import Rules Tighten Again: CBP's New Enforcement & What You Need to Know About E-Clearance

The U.S. Customs and Border Protection （CBP） issued new measures on August 19. Effective September 18, 2026, CBP is intensifying its verification of Importer of Record (IOR) data. Under these measures, if CBP finds that a business has submitted incomplete or inaccurate information on Form 5106, CBP may void the company's IOR Number.

Once an IOR Number is voided, the affected business loses the ability to use that identifier to file customs declarations in the United States.

CBP announced multiple import policies between August and September. Businesses with U.S. import needs should review these measures.

1. US Import Compliance: CBP Tightens Form 5106 and IOR Verification

Starting September 18, CBP is increasing verification of Form 5106 information. Because CBP relies on Form 5106 data to verify which entity acts as the Importer of Record, CBP requires that all information be authentic, complete, and tied directly to the actual importer.

A business must list its physical business address as its primary business address. Companies may not substitute this with the addresses of registered agents, customs brokers, freight forwarders, P.O. Boxes, business service centers, or third-party entities. Furthermore, submitted phone numbers and email addresses must be valid and belong directly to the IOR entity or individual; customs brokers and other third parties cannot substitute their own contact details.(Federal Register)

Failure to comply allows CBP to void the IOR Number directly. Once an IOR Number is invalidated, customs brokers can no longer use it to process U.S. customs entry declarations on behalf of the company, and goods already in transit may be unable to complete Entry.

To restore a voided IOR Number, businesses must submit supplementary identity documentation as requested in official CBP notices.

Consequently, importers that have not updated their Form 5106 in years should review their records. Any company that has relocated, or previously provided third-party contact information, such as a freight forwarder's or broker's details, should update the information.

Upon voiding an IOR Number, CBP issues a written notification to the email address most recently submitted to the agency, detailing the grounds for invalidation and listing the required documentation for reinstatement.

Businesses seeking to contact CBP regarding these matters can email IORProgram@cbp.dhs.gov with the subject line "Enforcing IOR Accuracy."(Federal Register)

Companies utilizing logistics service providers can also request assistance from their partners to verify whether their IOR Number remains active, whether their Form 5106 matches current operational details, and whether their licensed customs broker holds a valid Power of Attorney (POA) with accurate corporate information.

2. CBP Proposes Matching Overseas Export Records with U.S. Import Declarations

On September 2, CBP issued a notice considering whether to require importers to obtain or submit the foreign export documentation associated with their shipments. This proposed requirement covers export declarations, commercial invoices, packing lists, certificates of origin, permits, and bills of lading.

This proposal is currently in the public comment phase and has not yet taken effect.(Federal Register)

CBP is considering whether foreign export documentation could help verify and reconcile U.S. entry and entry summary information and identify discrepancies that could indicate violations of U.S. customs and trade laws, such as "dual invoicing," the practice of declaring different transaction values for the same shipment across jurisdictions. If future discrepancies exist between export and import data, importers may be required to explain the variance and provide supporting documentation.

3. New Electronic Customs Clearance Framework for International Postal Parcels Under $2,500

CBP will initiate testing for a new electronic entry format, Entry Type 13, starting September 22, 2026.

This voluntary test allows qualifying international postal shipments valued at or under $2,500 to undergo simplified electronic customs entry through the Automated Commercial Environment (ACE). Filers must supply details, including the IOR Number, a 10-digit HTS tariff classification code, country of origin, cargo value, applicable duty rates, and secure a customs bond.（CBP Federal Register）

Eligible low-value shipments subject to duty exemptions or supplemental tariffs (such as Section 301 tariffs) may utilize this process. However, commodities subject to Antidumping/Countervailing Duties (AD/CVD) or quota restrictions remain subject to formal entry procedures.

Businesses that regularly utilize international postal channels for small orders, product samples, or inventory replenishment should prepare HTS codes and regulatory documentation.

Consumer goods brands must also consider safety compliance rules. Beginning October 22, 2026, the U.S. Consumer Product Safety Commission (CPSC) will require importers of products requiring compliance certifications (such as children's products and toys) to submit electronic certificate data during Entry Type 13 processing. Importers must confirm they hold valid compliance documentation, such as Children's Product Certificates (CPC) or General Certificates of Conformity (GCC), prior to dispatch.（CPSC）

4. Enhanced Production and Regulatory Disclosures Required for Specific Commodities

Recent regulatory updates have introduced heightened entry requirements for specific product categories:

Mandatory Smelter and Cast Country Reporting for Select Copper Products: Beginning September 14, ACE will reject entry summaries if the required smelt and cast country information is not reported. If unknown, filers may input "OTH" (Other), but leaving the field blank is strictly prohibited. Importers of these commodities must verify sourcing details with their supply chains in advance.

Quarantine Inspections for Biological Materials and Samples: Following an increase in recent seizures, the USDA Animal and Plant Health Inspection Service (APHIS) issued a warning that research samples and biological materials containing animal-derived components or having prior animal contact may require appropriate permits or documentation prior to entry. Misrepresenting, failing to declare, or concealing such materials may lead to seizure, civil fines, or criminal prosecution.

FSVP Enforcement for Food Imports: The FDA recently updated its FSVP Import Alert list. U.S. food importers are required to verify that their overseas suppliers comply with U.S. food safety standards; failure to do so risks placement on an FDA Import Alert. Once placed on an import alert, subsequent shipments are subject to Detention Without Physical Examination (DWPE).

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