US IOR New Rules Effective September 18 | CBP Launches the Strictest Importer Qualification Verification in History, How Should US-Line Sellers Respond?
CBP Launches the Strictest Importer Qualification Verification in History, How Should US-Line Sellers Respond?
Since 2026, the US Customs has been tightening supervision at the import end layer by layer, with 5H/9H inspection upgrades, mandatory CPSC electronic declaration, and indefinite suspension of low-value duty-free policies. And the upcoming Executive Order No. 14411 will push US-line compliance to a whole new level.
On August 19, 2026, the US Customs and Border Protection (CBP) issued an official notice in the Federal Register, announcing that starting from September 18, 2026, Executive Order No. 14411 "Strengthening Customs Enforcement" will be fully implemented. CBP will carry out the strictest-ever verification of CBP Form 5106 (Importer Identity Information Form), and IOR numbers with inaccurate or incomplete information will face immediate invalidation.
What Is IOR?
IOR (Importer of Record) refers to the individual or company legally responsible for importing goods compliantly through US customs. Depending on the shipping method, the IOR may be the seller itself, the seller's company, a freight forwarder or a customs broker.
The core responsibilities of the IOR include:
Ensuring goods comply with US customs requirements
Paying applicable duties and taxes
Providing accurate import documents to CBP
Simply put, the IOR is the first object of accountability for US customs — whoever declares the import as IOR bears full legal responsibility for the compliance of this shipment.
2. Core Requirements of the New Rules: Comprehensive Information Verification
According to the CBP notice, starting from September 18, CBP will strictly verify all information filled in CBP Form 5106 by both new and existing importers. The following are the verification priorities:
1. Entity Physical Address
Must fill in the actual physical location of the enterprise; it is strictly prohibited to use a freight forwarder's address, agent address or PO Box as the IOR address. The address must be real and verifiable.
2. Contact Information Ownership
The email and contact phone must directly belong to the importer entity. Customs brokers and third-party forwarders must not replace and fill in their own contact information. The submitted email address must be valid and belong to the IOR.
3. Verifiable EIN/SSN
The IRS Employer Identification Number or Social Security Number must be accurate and verifiable through government agencies.
4. Information True, Unique and Timely Updated
All materials in CBP Form 5106 must be accurate and complete, and changes must be updated in the archive at the first opportunity.
5. Power of Attorney (POA) Compliant and Valid
Customs brokers must hold a valid POA directly signed by the IOR; third-party forwarders are not allowed to sign on their behalf. Customs brokers must fulfill their review and verification obligations and are prohibited from reporting false or unverified information.
3. Consequences of Violation: Invalidation, Penalties, Major Risks
After the new rules take effect, the consequences of violation are extremely serious:
1. IOR Number Directly Invalidated
If CBP determines that the CBP Form 5106 information is wrong, incomplete or untruthful, the IOR number immediately becomes invalid, and that entity can no longer handle US import declarations.
2. In-Transit Goods Cannot Clear Customs
After the IOR becomes invalid, in-transit goods cannot be cleared and enter the country normally, generating detention charges, storage fees, return shipping or even destruction costs, which can easily trigger commercial disputes and customer claims.
3. Risk of High Legal Penalties
Submitting false information will face fines under the False Claims Act, and serious cases will face criminal prosecution.
4. Joint Accountability of Customs Brokers
CBP regards customs brokers as the first verification party for IOR compliance. If brokers continue to declare while knowing the materials are false, they will bear joint responsibility and may even face license revocation.
4. Industry Impact: Gray Clearance Models Will Gradually Disappear
From an industry perspective, the implementation of the new rules will accelerate the industry's compliance reshuffle. Some non-compliant operations in the past will face direct cleanup. CBP's strict verification of IOR information authenticity means that the import entity of every shipment must be real, traceable and accountable. Practitioners without real IOR capability will be eliminated, and the traditional dual-clearance tax-inclusive model will also suffer a shock. This is the inevitable path of the industry from "gray clearance" to "sunshine compliance."
1. Foreign IORs Face Stricter Restrictions
According to the requirements of the executive order, foreign IORs will be prohibited from using informal entries (for goods valued under US$2,500). At the same time, foreign IORs may no longer be able to use annual continuous bonds to cover the year's goods, and each shipment may need to purchase a separate bond.
2. The Traditional Dual-Clearance Tax-Inclusive Model Suffers a Fatal Blow
A large number of operating models that rely on overseas forwarders as foreign IORs for dual-clearance tax-inclusive services will become unsustainable as bond, customs declaration and compliance costs rise sharply.
3. Heavier Due Diligence Responsibility for Customs Brokers
The thresholds for forwarder enterprise customer admission and document verification are comprehensively raised, and complete due diligence archives and authorization documents need to be retained.
5. Jinlian's Suggestions: 30-Day Countdown, Act Now
There is less than a month before the September 18 effective date. It is recommended that US-line sellers complete the following actions immediately:
1. Confirm IOR Identity
Contact your freight forwarder or customs broker and ask directly: "Is my Importer of Record (IOR) a US entity or a foreign entity?" Look through the customs declaration form (CBP Form 7501) or transport service agreement to verify IOR information.
2. Comprehensively Check CBP Form 5106 Archive
Verify all information currently filed with CBP — actual physical address, contact phone, email, EIN/SSN — to ensure it is completely consistent with the actual enterprise. If there are errors, correct and report to CBP immediately.
3. Confirm the Customs Broker's CTPAT Qualification
If you are a foreign IOR, does the customs broker handling your goods hold CTPAT (Customs-Trade Partnership Against Terrorism) certification? If not, you need to plan for a change in advance.
4. Check the Bond Type
Confirm whether you are using an annual continuous bond or a single transaction bond. Foreign IORs may need to budget for higher single-batch bond fees.
5. Standardize the POA Authorization Relationship
Confirm that the customs broker holds a valid POA directly signed by the IOR, prohibit third-party signature on behalf, and refuse to use shared or virtual IOR entities for declaration.
6. Establish a Dynamic Information Update Mechanism
Once the enterprise address or contact information changes, submit the update to CBP at the first opportunity through the ABI interface or email; do not wait until problems arise to remedy.
The enforcement signal of Executive Order No. 14411 is already very clear — US customs is extending importers' compliance responsibility from the "declaration link" to "full-lifecycle management of entity qualifications," from address verification to contact information verification, from POA authorization to bond types; every threshold is rising.
For the vast majority of US-line sellers, compliance is no longer a multiple-choice question, but a required question. It is recommended to complete the following preparations as early as possible: confirm your IOR identity and the authenticity and completeness of CBP Form 5106 filing information, verify the customs broker's CTPAT qualification, understand the current bond type in use, and collect business information such as enterprise ownership and beneficial owners in advance. The earlier you complete the compliance self-check, the more calmly you can respond when the policy officially lands, avoiding economic losses caused by in-transit cargo detention.
Going Global Compliantly, Choose Jinlian
In terms of compliant customs clearance, the Jinsuda supervised warehouse channel of Jinlian International Logistics supports customers to clear customs under their own company name, with single-shipment single-clearance — every shipment is independently declared and cleared, completely isolated from other goods. Under this model, inspection risks are controllable and responsibility boundaries are clear, making it particularly suitable for sellers with high compliance requirements who want to control the entire customs clearance process. Jinlian International has been deeply cultivating the US line for many years, with a professional compliance team and customs clearance resources. If you have any questions about the US IOR new rules, or need assistance in verifying IOR information and confirming customs broker qualifications, please feel free to contact the Jinlian team at any time. We will provide you with professional compliance consulting and customs clearance solutions to escort your goods safely into the US market.