CBP Form 5106 Requirements

The Importer Identity Form serves three primary functions within CBP's trade compliance framework. It establishes your identity within CBP's Automated Commercial Environment (ACE), assigns or confirms your Importer of Record (IOR) number, and links your taxpayer identification to all formal entries you submit or are named on.

Unlike many government forms, Form 5106 is not filed with every shipment. It is filed once to establish your record, and then updated whenever your identifying information changes. Your importer record remains active as long as you continue importing. Under 19 CFR 24.5, an importer number that goes unused is removed from the system after one year, requiring a new filing before you can resume importing activity.

Under 19 CFR 24.5, any person, business, government agency, or organization must file CBP Form 5106 with their first formal entry or with the first request for CBP services that results in a bill or refund. The requirement applies broadly across entity types and transaction roles.

U.S. Individuals and Businesses

• First-time importers establishing an Importer of Record number prior to their initial formal entry

• Sole proprietors, partnerships, corporations, and LLCs conducting commercial import activity

• Businesses updating legal name, mailing address, physical location, or taxpayer identification on file with CBP

• Consignees and ultimate consignees listed on a formal customs entry — including those who did not initiate the shipment

• Importers seeking access to the ACE Secure Data Portal for IEEPA tariff refund filings

Foreign Entities

• Foreign companies appointing a U.S. agent or customs broker to act on their behalf for import transactions

• Foreign sellers acting as the Importer of Record under DDP (Delivered Duty Paid) Incoterms arrangements

• Non-U.S. residents who do not have an IRS EIN or Social Security Number — these parties may request a CBP-assigned identification number through Form 5106

E-Commerce and Platform Sellers

• Amazon FBA sellers who import merchandise directly from overseas manufacturers or suppliers

• Shopify, Etsy, and other platform sellers importing goods for fulfillment in the U.S.

• Dropshippers whose customers receive direct international shipments valued over $2,500

While Form 5106 is not submitted with every shipment, there are specific events that require a new filing or an update to an existing record. Understanding these triggers helps importers avoid delays, holds, and rejected entries.

The form collects identity, business structure, and compliance data across three primary sections. Gathering all required information before beginning the form reduces errors and prevents CBP from rejecting or delaying your submission.

Section 1 — Identity and Tax Identification

• Type of action — New filing, name change, address change, reactivation, or other update

• Legal name — Full legal name of the individual or business entity exactly as registered

• Employer Identification Number (EIN) — Required for all business entities; becomes the IOR number

• Social Security Number (SSN) — Required for individuals filing without an EIN

• CBP-Assigned Number — Required if one has previously been assigned; for foreign entities without U.S. tax IDs

• Type of company — Corporation, LLC, partnership, sole proprietor, government agency, or other organization

• Estimated annual import entries — Your projected volume of formal entries per year

• Role of party — Importer of Record, consignee, broker, carrier, or other party type

Section 2 — Address Information

• Mailing address — Street address or PO Box; must be completed on all filings

• Physical location — Required when mailing address is a PO Box

• Foreign address details — Province, postal code, and country for non-U.S. addresses

• Contact information — Phone number and point of contact name for CBP correspondence

Section 3 — CBP Partnership Programs

• CTPAT participation — Customs-Trade Partnership Against Terrorism membership, if applicable

• ISA enrollment — Importer Self-Assessment program participation, if applicable

• Broker/self-filer code — Filer code used when conducting business directly with CBP

• Attorney-in-Fact / Power of Attorney — Required if the form is signed by a representative rather than the importer directly

CBP accepts Form 5106 submissions through several channels. The correct submission route depends on whether you are a first-time importer, an existing importer updating your record, or a foreign entity without U.S. tax identification.

1. 1

   Prepare Your Completed Form

   Complete all required sections. Ensure your legal name, EIN or SSN, address, and entity type are accurate and consistent with your CBP records. If using a customs broker or preparation service, they complete the form based on information you provide.

2. 2

   Sign and Certify

   The form must be signed by an authorized officer of the business or the individual importer. If a third party signs on your behalf, a current Power of Attorney must accompany the submission.

3. 3

   Submit to the Correct CBP Center

   Email your completed form to the CBP Center of Excellence and Expertise that handles your commodity type or geographic region. The email must include the correct subject line format: "5106 — [Importer Name] — [EIN/SSN]" or as directed by your applicable CBP Center. Incorrect subject lines are a common cause of processing delays.

4. 4

   Receive Confirmation

   CBP sends an auto-reply confirming receipt of your submission. If you do not receive this confirmation within 2 business days of submission, assume the email was not received and resubmit. CBP's Revenue Division Bond Team (RDBT) has up to 5 full business days to process submissions.

CBP processing timelines vary based on whether a submission is a new filing or an update to an existing record. It is strongly recommended to submit your Form 5106 before your first shipment arrives at the port of entry to avoid holds, storage fees, and delayed clearance.

CBP does not offer expedited processing for Form 5106 submissions made directly. For importers who need their record established quickly prior to a shipment deadline or tariff refund claim, submitting early is the only reliable way to ensure timely processing.

Once your importer record is established with CBP, you are not required to refile with every shipment. However, the information on file must remain accurate. Any change to your identifying information requires a new Form 5106 submission indicating the type of change.

Changes That Require an Updated Filing

• Legal business name change

• DBA or trade name change

• Mailing address change

• Physical location change

• Change in EIN or SSN

• Change in entity type

• New points of contact

• Opening branch offices

• Adding or changing broker/filer codes

• Reactivating an inactive importer number

Inactive Importer Numbers

Under 19 CFR 24.5, an importer identification number that has not been used in connection with a customs transaction for a period of one year will be removed from the system. If your number has been removed, you must submit a new Form 5106 to reactivate it before you can resume importing. There is no penalty for reactivation, but your entry will not be processed until the form is on file and active.

Freezing Your Importer Record

Importers who want to prevent unauthorized changes to their name and address information on file may request CBP to "freeze" the record under 19 CFR 24.5(f). A frozen record can only be modified by a designated authorized individual at the company. To freeze your record, you must provide CBP with the name and title of the authorized individual and the specific Importer Record Numbers to be frozen.

As of 2025, CBP Form 5106 has taken on additional significance for importers seeking refunds on tariffs paid under the International Emergency Economic Powers Act (IEEPA). Importers who overpaid tariffs on certain goods subject to IEEPA orders may file for a refund through the ACE Secure Data Portal using a CAPE (Customs Automated Protest and Entries) Declaration.

Before any refund claim can be submitted or processed, an active Form 5106 must be on file with CBP. The form establishes your identity within CBP's ACE system, which is the required platform for accessing the refund portal. Importers without an active Form 5106 cannot access the ACE Portal and cannot submit CAPE Declarations.

If your importer number has been inactive for more than one year, it will have been removed from CBP's system. You must reestablish your record by filing a new Form 5106 before you can access the refund portal. Given that CBP processes new records within approximately 2 business days, it is strongly advised to confirm your record is active before refund deadlines approach.

The majority of Form 5106 processing delays and rejections are caused by a small set of avoidable errors. Reviewing these before submission significantly reduces the likelihood of a hold on your entry or refund.