The Type of Action block at the top of CBP Form 5106 tells CBP what to do with the record. Checking the wrong box, or leaving the right one blank, is one of the most common reasons a filing is returned. Three boxes are available, and more than one can apply.
Notification of Identification Number
Check this box when CBP has no active record for you. That covers two situations: a first filing, where no importer number has ever been created, and a reactivation, where a number was issued in the past but has gone inactive because it was not used on an entry or payment. In both cases CBP treats the filing as creating or restoring the record.
This is the box most filers need. If you are filing to gain ACE Portal access for a tariff refund and have never imported formally before, this is your box.
Change of Name
Check this box when an importer number is already on file and the legal name has changed. The name on the record must match the name registered with the IRS for the EIN, so a business that has reorganized, merged, or re-registered under a new name files this update before any entry or refund can be processed under the new name.
A name change alone does not create a new number. The existing number carries over.
Change of Address
Check this box when an importer number is already on file and the mailing address or physical location has changed. CBP uses the address on record for correspondence, bills, and refund checks, so an outdated address delays every one of those.
When to check more than one
Name and address often change together, and both boxes should be checked in that case. A first filing never combines with the other two; if the record is new, only Notification applies.
When to leave all three blank
Updates that do not involve the name or address, such as a new phone number, a new email, or added company officers, are submitted with all three boxes blank. CBP reads a blank Type of Action as an update to an existing record.
A note on active bonds
If the importer has an active continuous bond on file and is changing its name or address, CBP requires a bond rider to accompany the Form 5106 unless the bond is covered by an exemption such as the eBond program. Filing the form without the rider delays the change.
Next step
The questionnaire asks why you are filing in plain language and sets the correct Type of Action boxes from your answer. The completed form is delivered by email with the CBP submission instructions for your filing type.