U.S. import compliance is moving into a more data-driven phase.

Two recent U.S. Customs and Border Protection actions, enhanced enforcement of Importer of Record information and a new initiative focused on supply chain visibility, show a common direction: CBP wants more accurate importer identity data and deeper visibility into the parties, documents, and information behind goods entering the United States.

Both actions trace back to Executive Order 14411, Strengthening Customs Enforcement. But importers need to understand an important distinction: the September 18, 2026 Importer of Record enforcement measure is moving forward, while CBP’s newer supply chain initiative is an Advance Notice of Proposed Rulemaking (ANPRM). The latter is seeking industry input and does not yet establish final mandatory disclosure requirements.

September 18: CBP Will Enforce Form 5106 Accuracy

In its August 19 notice, CBP announced enhanced enforcement procedures for information submitted by new and existing Importers of Record through CBP Form 5106.

Beginning September 18, 2026, CBP says it will immediately void an IOR number when it determines that the information provided is inaccurate or incomplete. A voided number becomes invalid for any purpose, including entering imported merchandise into the United States. Importers can review the official Federal Register notice on Importer of Record data accuracy and the official CBP Form 5106.

Form 5106, the Create/Update Importer Identity Form, is used to establish or update an importer’s identity with CBP. Required information includes the importer name, EIN, SSN or CBP-assigned number, mailing address, physical location when different, phone number, and email address.

CBP is particularly clear about contact information. The physical address must represent the actual location of the business or individual; it cannot simply be the address of a registered agent, customs broker, freight forwarder, P.O. box, business service center, or another entity.

The email address and phone number must also belong to the IOR. Brokers submitting Form 5106 must have a valid Power of Attorney executed directly with the importer.

If an IOR number is voided, CBP says it will send written notice to the most recently submitted importer email address and explain how reestablishment can be requested. Industry analyses from Diaz Trade Law and C.H. Robinson have highlighted the operational concern: an importer may face disruption if an IOR problem is discovered when an entry needs to be filed.

CBP’s Next Focus: Greater Supply Chain Visibility

On September 2, CBP published its Heightened Import Disclosures for Supply Chain Visibility ANPRM under docket USCBP-2026-1058. Interested parties can also review the official Regulations.gov docket. Comments are due December 1, 2026.

This is an important distinction for importers: CBP is asking questions and considering potential regulations. The disclosure concepts described in the ANPRM are not yet final requirements.

Among the issues under consideration is whether importers should submit or retain documentation provided to foreign customs authorities. CBP identifies potential records such as foreign export declarations, commercial invoices, packing lists, certificates of origin, export permits or licenses, and transportation documents.

CBP is also examining how it identifies parties throughout an international transaction. The agency asks whether it should collect more information about manufacturers, shippers, exporters, sellers, producers and, potentially, online marketplaces or the party ultimately receiving merchandise.

Another area under review is whether the traditional Manufacturer Identification Code (MID) provides sufficient visibility. CBP is seeking feedback on Global Business Identifiers and other entity- or product-level identifiers that could provide more consistent information about manufacturers, sellers, shippers and imported products.

Technology Could Become Part of Customs Visibility

The ANPRM goes beyond documentation.

CBP is asking the trade community about technologies already being used to trace supply chains, verify production information and identify raw-material origins. Questions also address artificial intelligence, integration with the Automated Commercial Environment (ACE), tamper-resistant credentials and the ability to verify country-of-origin information.

CBP is even considering whether CTPAT requirements and benefits should evolve around supply chain traceability, cybersecurity and data integrity.

The agency’s stated objective is to improve its ability to detect illicit imports and illegal transshipment, particularly when goods are routed through another country in an attempt to obscure their true origin or evade U.S. customs and trade requirements.

How the Two CBP Actions Connect

The Form 5106 enforcement action and the supply chain visibility ANPRM are separate measures, but they represent two sides of the same customs-enforcement strategy.

The first asks: Who is the Importer of Record, and can CBP accurately identify and contact that party?

The second goes deeper: Who manufactured, sold, shipped and exported the merchandise, what documentation exists throughout that transaction, and how reliably can the supply chain be traced?

Both are connected to Executive Order 14411 and its broader emphasis on importer accountability, customs fraud, rules of origin, revenue collection, forced labor, product safety and trade-law enforcement.

GLC previously examined the broader implications of that Executive Order in our article, New Customs Enforcement Order: What Importers Should Review Now. The latest CBP actions provide more concrete evidence of how that enforcement strategy is beginning to develop.

What U.S. Importers Should Review Now

Importers should not treat the ANPRM as though its ideas are already mandatory. However, the direction of CBP’s questions provides a useful framework for strengthening customs readiness now:

• Verify Form 5106 data and confirm the physical address, telephone number, email and identification information belong directly to the IOR.
• Confirm customs broker Powers of Attorney are current, valid and executed directly with the importer.
• Review product and supplier master data for consistent manufacturer, seller, shipper, country-of-origin, classification and product-description information.
• Assess access to foreign export documentation and whether that information can be reconciled with U.S. import records.
• Map critical customs data across the supply chain so suppliers, logistics teams and customs representatives are working from consistent information.

These steps support current compliance while also helping businesses prepare if CBP eventually moves from the ANPRM to a formal proposed rule.

How GLC Inc. Supports Importers in a More Data-Driven Customs Environment

For companies managing regular U.S. imports, these developments reinforce an important principle: customs brokerage should be integrated into supply chain planning, not treated as a final administrative step when cargo is already approaching the border.

GLC Inc.’s Customs Brokerage services support importers with entry processing, Importer Security Filing, classification support, Partner Government Agency coordination, continuous and single-entry bond coordination, duty drawback, customs reporting and release coordination.

GLC also provides automated customs-entry and cargo-release notifications, customized reporting, and access to customs documentation and shipment status through the Neo Portal. These capabilities can help importers maintain better coordination between product information, shipment documentation and customs activity.

As CBP emphasizes better importer identification today and considers deeper supply chain visibility for tomorrow, organized information and early coordination become increasingly important.

Final Takeaway: Prepare for September 18 and Watch What Comes Next

The immediate priority is clear: U.S. importers should confirm that their Form 5106 information is accurate before enhanced enforcement begins September 18, 2026.

At the same time, CBP’s supply chain visibility ANPRM deserves close attention. It signals potential future expectations around foreign export documentation, party identification, traceability, product data and technology.

Importers that strengthen documentation quality, supplier visibility and customs coordination now may be better prepared if those concepts move into formal rulemaking.

Need support reviewing your U.S. import process, customs documentation or entry coordination? Request Customs Brokerage support from Global Logistical Connections. GLC helps connect customs compliance with the broader movement of your international supply chain.