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A New Dawn of CBP Enforcement

Your resource for navigating increased CBP enforcement, evolving compliance requirements, and the actions importers need to take now.

What Importers Need to Know Before September 18th

CBP is entering a new era of importer accountability.
 
Following recent enforcement initiatives and updated importer identity requirements, CBP is increasing scrutiny of Importer of Record (IOR) information and taking new steps to verify importer identities. Beginning September 18, 2026, inaccurate or incomplete importer information may result in an Importer of Record number being voided, potentially disrupting entry processing and delaying shipments.

The good news?

We've gathered the key information, practical guidance, and resources you need in one place. Below you'll find expert videos, recommended actions, and helpful CBP resources to help you prepare with confidence.
 
Let's navigate this new enforcement environment together.

Your Priority Action Items

We recommend that all importers complete the following actions as soon as possible:

Open an ACE Portal Account

An ACE Portal account helps you monitor entries, review CBP communications, and verify critical importer information. If you do not yet have an ACE Portal account, use this resource to get started. 
ACE Portal Account

Review and Verify Your CBP Form 5106 Information

CBP is placing increased emphasis on the accuracy of importer information maintained through CBP Form 5106. Importers should review their current information and promptly update any outdated or incomplete data to help avoid potential disruptions to import operations.

Confirm Your Importer Email Address, Phone Number, EIN, and Physical Address Are Accurate

CBP is placing increased emphasis on the accuracy of importer information maintained through CBP Form 5106. Importers should review their current information and promptly update any outdated or incomplete data to help avoid potential disruptions to import operations.

Explore CBP's Freeze Program

Once your importer information has been verified and updated, you may wish to consider CBP's Freeze Program. The program allows importers to limit who is authorized to make changes to their importer information, helping protect against unauthorized updates and strengthening control over importer records.

Evaluate CTPAT Participation

CBP has indicated that participation in the Customs Trade Partnership Against Terrorism (CTPAT) program may help facilitate the movement of cargo into the United States while demonstrating a commitment to supply chain security and customs compliance. Importers should consider whether participation in the program aligns with their business needs and compliance objectives.

Enroll in ACH

Pay duties directly to CBP and receive refunds directly to your designated bank account. If you do not yet have an ACH account, use the ACH Enrollment Guide to get started. 
ACH Enrollment

The New World of Enforcement & Importer Identity

Join Amy Magnus and Sandy Coty as they breakdown what action importers need to take to navigate the new CBP enforcement. 
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Resource Links

Regulatory & Enforcement Resources

Strengthening Customs Enforcement Executive Order
https://www.whitehouse.gov/presidential-actions/2026/06/strengthening-customs-enforcement/ 

Federal Register: Accuracy of Importer of Record Data Submitted to CBP (5106 Rule)
https://www.federalregister.gov/documents/2026/08/19/2026-16911/accuracy-of-importer-of-record-data-submitted-to-cbp6

CBP: Strengthening Customs Enforcement
https://www.cbp.gov/trade/strengthening-customs-enforcement 

ACE Portal Resources

Apply for an ACE Portal Account
https://www.cbp.gov/trade/automated/how-to-use-ace/portal-applying 

Manage an ACE Portal Account
https://www.cbp.gov/trade/automated/how-to-use-ace/portal-managing 

ACE Account Review / Trade Account Owner Updates
https://aceaccountreview.cbp.gov/ 

ACE Portal User Management Guide
https://www.cbp.gov/document/guidance/ace-portal-user-management 

ACH & Refund Resources

ACH Enrollment Information
https://www.cbp.gov/trade/automated/ach/signing 

CBP Form 5106 Resources

CBP Form 5106
https://www.cbp.gov/sites/default/files/2026-06/cbp_form_5106.pdf 

Voided Importer of Record FAQs
https://www.cbp.gov/trade/priority-issues/revenue/bonds/voided-importer-record-faqs

Freeze Program Resources

CBP Freeze Program
https://www.cbp.gov/trade/priority-issues/revenue/bonds/freeze-program 

CTPAT Resources

Apply for CTPAT
https://www.cbp.gov/border-security/ports-entry/cargo-security/c-tpat-customs-trade-partnership-against-terrorism/apply

Contact Information

IOR Program Questions
IORProgram@cbp.dhs.gov 
ACE Support
ace.support@cbp.dhs.gov 
Freeze Program Requests
bondquestions@cbp.dhs.gov 

 

Your ACE Portal Guide

In the video below, Sandy Coty provides a guided walkthrough of the ACE Portal and shows you exactly how to complete the required tasks.

Browse Additional Resources

Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates. 
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